United States v. Guillen, No. 20-2004 (10th Cir. 2021)
Annotate this CaseAfter a young woman found a pressure cooker bomb hidden under her bed, law enforcement agents went to the home of the only person she said might want to harm her: defendant-appellant Ethan Guillen. The agents entered Ethan’s home, questioned him, and obtained consent from his father to search the residence. During the search, the agents found evidence in Ethan’s bedroom indicating his involvement with the pressure cooker bomb. When one of the agents confronted Ethan with the information and evidence they had collected, he confessed to making the bomb. The agent immediately provided Ethan Miranda warnings, but he proceeded to make more incriminating statements. Ethan ultimately entered a conditional plea of guilty to possession of an unregistered destructive device and an attempt to damage or destroy a building by means of fire or an explosive. His plea agreement reserved the right to appeal the district court’s order denying his motion to suppress the physical evidence and incriminating statements resulting from the search of his home. Exercising that right, Ethan argued to the Tenth Circuit that the district court should have suppressed the physical evidence found in his home because the agents’ warrantless entry and search of his bedroom violated his Fourth Amendment rights. He also contended the district court should have suppressed the incriminating statements he made after receiving Miranda warnings because the agents elicited them through coercion and used an impermissible two-step interrogation technique to end run around Miranda. Finding no violation of his rights or any other reversible error, the Tenth Circuit affirmed the district court's judgment.
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