United States v. Haak, No. 16-3876 (2d Cir. 2018)Annotate this Case
The Second Circuit reversed the district court's order suppressing statements that defendant made to law enforcement authorities in the course of a non-custodial interview on March 4, 2015. The court reviewed the totality of the circumstances as reflected in a videotape recording of the interview at issue and held that defendant's statements were not coerced. In this case, the police did not falsely promise defendant immunity from prosecution in return for his cooperation and, in the absence of such a promise, nothing demonstrated that defendant's will was overborne during his non-custodial interview as to render the statements he made at that time constitutionally involuntary.