United States v. Williams, No. 13-2390 (8th Cir. 2014)
Annotate this CaseThe United States appealed the district court's suppression of statements and evidence gathered during the search of defendant's home and car. Defendant was charged with two counts of receipt and one count of possession of child pornography. The court concluded that defendant's statements and consent were voluntary where the agent who interviewed defendant and requested his consent to search did not make threats or promises, use deceptive tactics, or even raise his voice. Additionally, defendant spoke clearly, was coherent, and appeared to understand what was happening. Therefore, the court reversed the district court's suppression of the statements.
Court Description: Criminal case - Criminal law. The district court erred in suppressing statements and evidence gathered during the search of defendant's home and car; the district court erred in finding defendant was in custody at the time he made certain statements as defendant was unrestrained in his own home, had been advised he was not under arrest and had been told that any any participation in the interview was voluntary; under such circumstances a reasonable resident would have known he was free to leave or terminate the questioning; shorn of the erroneous legal conclusion about custody, the record established defendant's statements and consent were voluntary, and the district court erred in granting defendant's suppression motion.
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