United States v. Daniels, No. 13-3481 (8th Cir. 2014)
Annotate this CaseA.C. saw people outside her apartment building, including Daniels and Hudson. A.C. left. Returning, she learned that there had been an altercation. As a neighbor was explaining, Daniels and Hudson approached, angrily demanding to find certain individuals. Daniels brandished a handgun and threatened A.C. Her brother approached. Daniels fired a shot toward him before fleeing. Officers responded, drove to Hudson’s house, and detained Daniels and Hudson. Executing a warrant, they recovered the handgun that had fired the casing found near A.C’s building and ammunition with the same stamping as that casing. While 92% of the population could be excluded as a contributor to DNA from the handgun, Daniels was not excluded. Sergeant Lambie read Daniels his Miranda rights. Daniels initialed the Miranda advisories, signed a waiver form, and voluntarily admitted to shooting the gun, appearing alert. The interview was recorded. The court denied Daniels’ motion to suppress. Days before trial, the government first learned that a video recording existed of Daniels and Hudson in the squad car, eight hours before the Lambie interview. Daniels alleged that it showed him intoxicated, so that his statements were involuntary. The court denied Daniels’ motions. He was convicted as a felon in possession of a firearm and sentenced as an armed career criminal to 204 months, below the Guidelines range of 262 to 327 months. The Eighth Circuit affirmed, rejecting challenges to admission of Daniels’s statements and to the sentence.
Court Description: Criminal case - Criminal law and sentencing. Defendant was coherent and responsive when he made his post-Miranda statements and there was no evidence that he was coerced or threatened; as a result, the statements were admissible because he had voluntarily and knowingly waived his rights; district court did not err in denying a motion to reopen the suppression hearing based on the discovery of a video as the video supported the court's earlier conclusions; no error in sentencing defendant as an armed career criminal; sentence was not substantively unreasonable.
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