United States v. Outland, No. 20-1160 (7th Cir. 2021)Annotate this Case
Defendant appealed the district court's denial of his motion to suppress incriminating statements which led to federal charges for distributing heroin. In this case, after defendant overdosed on heroin and fell unconscious, officers brought him to a local hospital where, after receiving care, he agreed to talk to the police, received Miranda warnings, and made several incriminating statements.
The Seventh Circuit remanded for the district court to make a determination on the validation of defendant's waiver of his Miranda rights in the first instance. The court explained that whether a defendant knowingly and intelligently waived his rights at the outset of a police interview is a distinct and separate inquiry from whether, in the circumstances of the interview as a whole, the defendant's statements were voluntary. Given defendant was unconscious and entirely incapacitated from an overdose just two hours before police questioned him, a finding as to whether defendant knowingly and intelligently waived his Miranda rights matters.