United States v. Campbell, No. 22-3283 (7th Cir. 2024)
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Joshua Campbell sought to suppress evidence of child pornography found during an unannounced parole check by his parole officers. He argued that his Fifth Amendment rights were violated because his parole agreement and the officers' failure to issue Miranda warnings led to the incriminating statements. Campbell contended that the parole agreement compelled his responses under threat of penalty and that he was in custody during the interrogation.
The United States District Court for the Northern District of Indiana denied Campbell's motion to suppress the evidence. The court found that the parole agreement did not threaten to penalize Campbell for invoking his Fifth Amendment rights and that he was not in custody at the time he made the incriminating statements. Campbell entered a conditional guilty plea, preserving his right to appeal the district court's decision.
The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the parole agreement did not impose a penalty for invoking the Fifth Amendment, as it only required Campbell to respond to communications from parole officers, which could include invoking his Fifth Amendment rights. Additionally, the court determined that Campbell was not in custody during the parole check, as he was in a familiar environment, not physically restrained, and the officers did not display weapons or use force. Therefore, the court concluded that Campbell's Fifth Amendment rights were not violated, and the evidence obtained during the parole check was admissible.
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