United States v. Quiroz, No. 16-3518 (7th Cir. 2017)Annotate this Case
Quiroz brokered large drug transactions and, in 2015, was convicted for his role in a methamphetamine transaction. In a second trial that year, he was convicted for his role in a marijuana transaction. Before each trial, Quiroz moved to suppress statements he made after his arrest, arguing that he was not read his Miranda warnings. The arresting officer testified that he read Quiroz his Miranda rights, that Quiroz seemed to understand, and that Quiroz made inculpatory statements after being told about recordings of his conversations. The district court found that the warnings were given and that Quiroz voluntarily waived his rights and admitted the statements into evidence. The court also admitted, under the hearsay exception for co-conspirator statements, recorded conversations between Quiroz and the government’s confidential informant, and recordings of other declarants. The Seventh Circuit affirmed. The totality of the circumstances in the record shows that Quiroz understood his rights even though he did not explicitly acknowledge that understanding. The court was permitted to consider the out-of-court statements, so long as it had some independent evidence of the conspiracy. In both cases, it did. Its finding of a conspiracy was not clearly erroneous.