United States v. Williams, No. 14-2949 (8th Cir. 2015)
Annotate this CaseWilliams was arrested at a motel, following a sting operation to locate a missing minor female, who police believed was being prostituted online. In Williams' motel room, police found the missing girl, a second girl, condoms, and the cellular phone that an undercover officer called earlier to arrange a paid "date" with the girls. After Williams was in handcuffs, detective Slaughter read his Miranda rights. Detective Slaughter testified that Williams stated he understood the admonitions and agreed to waive his right not to speak. Williams asked Slaughter whether he could remove belongings from his rental car. Slaughter asked whether there was anything illegal in the vehicle. Williams responded that he had a registered firearm and gave verbal consent to search. Williams watched the search, and did not withdraw consent. Police found a firearm, condoms, and electronic devices. Later, during a recorded interview, Slaughter summarized his contact with Williams and stated that Williams had been read his Miranda rights. Williams acknowledged and agreed with Slaughter's statements. Williams voluntarily consented and officers began searching the electronic devices. Almost six hours later, officers asked Williams for written consent. Williams refused and requested a lawyer. The officers stopped questioning Williams and secured warrants for the devices. The Eighth Circuit upheld denial of a motion to suppress and rejected a claim of vindictive prosecution.
Court Description: Beam, Author, with Gruender and Benton, Circuit Judges] Criminal case - Criminal law. No error in concluding defendant voluntarily waived his Miranda rights; even if the police did threaten defendant with obstruction-of-justice charges, such a threat would not automatically make his statements involuntary, and here defendant failed to show that under the totality of the circumstances the officers' statements overbore his will and capacity for self-determination; claim of vindictive prosecution rejected as there is no evidence that the prosecutor filed a superseding indictment to punish defendant for exercising his right to trial.
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