United States v. Ferguson, No. 19-1723 (8th Cir. 2020)
Annotate this Case
The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress and defendant's conviction for one count of arson related to a fire at a trailer home.
In regard to the motion to suppress, the court held that defendant was not in custody for the purposes of Miranda protections during a polygraph examination and subsequent interview. In this case, defendant came voluntarily to the justice center to take the test; he was read and signed the authorization form, which reiterated that he could refuse to take the test, decline to answer questions, end the test at any time, and have an attorney present; and defendant's movement was not restrained. Because defendant was not in custody, he was not entitled to Miranda protections of the right to remain silent and the right to counsel. To the extent defendant asserts that his incriminating statements were involuntarily made, primarily due to his low cognitive functioning, the court agreed with the district court that defendant voluntarily provided the statements after the polygraph examination. The court also held that the evidence was sufficient to support defendant's conviction where defendant's incriminating statements, combined with the testimony of other witnesses, provided a sufficient basis for a jury to find defendant guilty beyond a reasonable doubt.
Court Description: [Shepherd, Author, with Smith, Chief Judge, and Melloy, Circuit Judges] Criminal case - Criminal law. Defendant was not in custody at the time he took a polygraph test and made post-polygraph incriminating statements; among other factors to be considered on the issue, defendant was aware of his right to leave the exam and exam room and twice exercised his right to leave; as defendant was not in custody, he was not entitled to the Miranda protections of the right to remain silent and the right to counsel; the district court did not err in finding defendant's statements were voluntary; evidence was sufficient to support defendant's arson conviction; as the statute specifically criminalizes attempted arson, defendant's argument that there was no evidence the structure actually ignited is rejected.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.