United States v. Stadfeld, No. 11-1369 (7th Cir. 2012)
Annotate this CaseMortier was a major marijuana distributer with a network of street-level sellers around Madison, Wisconsin. He disappeared in 2004, and the District Attorney’s Office opened a John Doe proceeding to determine whether a crime had been committed. Prosecutors subpoenaed Mortier’s known drug associates, including Stadfeld. Rather than assert his right to remain silent and follow the steps necessary to obtain formal immunity, he talked to investigators informally in exchange for an oral nonprosecution agreement. Stadfeld’s counsel mistakenly advised him that this nonprosecution agreement immunized him against the use of his statements by state or federal prosecutors. Almost four years later, based in part on his statements to the investigators, Stadfeld was indicted by a federal grand jury for conspiracy to distribute marijuana. The district court denied a motion to suppress. Stadfeld was convicted. The Seventh Circuit affirmed. Stadfeld’s statements were not the product of law-enforcement coercion, and the erroneous advice from his lawyers did not make his statements involuntary or inadmissible based on ineffective assistance of counsel. To the extent that Stadfeld thought he had a comprehensive immunity agreement, it was conditioned on his telling the truth and he breach it by lying to investigators.
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