United States v. Santistevan, No. 11-1534 (10th Cir. 2012)
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The government appealed a district court order granting Defendant-Appellee Manuel Santistevan's motion to suppress statements made after invoking the right to counsel. Defendant was indicted on three counts of interference with commerce by robbery, using and carrying a dangerous weapon during the commission of a violent crime, possession of a firearm by a previously convicted felon, and possession of a short-barreled shotgun. The district court held that Defendant unambiguously invoked the right to counsel when he gave an agent of the Federal Bureau of Investigation ("FBI") a letter from his attorney indicating that he did not wish to speak without counsel. Because the agent continued to interrogate Defendant, the district court suppressed the incriminating statements that Defendant subsequently made. Upon review of the record, the Tenth Circuit concluded that Defendant indeed unambiguously invoked the right to counsel when he gave the letter drafted by his attorney to the agent, and affirmed the district court in suppressing the statements.
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