United States v. Azua-Rinconada, No. 17-4344 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed the district court's denial of defendant's motions to suppress evidence obtained by law enforcement officers during their encounter with him prior to his arrest. The court held that the district court did not clearly err in finding that the officers received voluntary consent from defendant's fiancee to enter his residence. Therefore, the entry did not violate the Fourth Amendment.
The court also held that defendant's freedom of action was not curtailed to a degree associated with formal arrest, and thus he was not in custody and Miranda warnings were not required. Accordingly, the district court did not err in concluding that defendant was not subject to custodial interrogation in violation of the Fifth Amendment.