United States v. Neiman Adams, No. 14-3339 (8th Cir. 2016)
Annotate this CaseDefendant appealed his conviction and sentence for armed bank robbery and violating the terms of supervised release imposed following an earlier conviction. Defendant argued that the district court clearly erred when it found that his statement, “I don’t want to talk, man,” was not an unequivocal invocation of his right to remain silent. However, defendant thereafter continued to talk to law enforcement, never clarifying his earlier statement or otherwise unequivocally invoking his right to remain silent. The court concluded that the district court did not commit clear error in finding that defendant had not indicated a clear, consistent expression of a desire to remain silent; the district court did not err in concluding that defendant had waived his Miranda rights; and that, in light of the circumstances, defendant's waiver was voluntary. In any event, any error in denying the motion to suppress would have been harmless. The court also concluded that the district court did not abuse its discretion in placing more weight on some mitigating factors and less weight on others. Finally, the court found no merit in defendant's argument that his consecutive 18-month revocation sentence is substantively unreasonable because the district court did not identify which sentencing factors it considered in imposing the sentence and did not take into account those previously listed mitigating factors. Accordingly, the court affirmed the judgment.
Court Description: Wollman, Author, with Bye and Gruender, Circuit Judges] Criminal case - Criminal law and sentencing. Defendant's statement to the FBI agent during a post-Miranda custodial interrogation that "I don't want to talk, man" was not an unequivocal invocation of the right to remain silent in light of defendant's further comment indicating a desire to clarify that statement and his subsequent sixteen minute conversation with the agent during which time he never further clarified his earlier statement or otherwise unequivocally invoked his right to remain silent; as a result the district court did not err in finding defendant had not indicated a clear, consistent expression of a desire to remain silent; nor did the court err in finding defendant had waived his Miranda rights by answering the agent's questions; the officers used no coercive tactics, defendant knew his rights and was familiar with police interrogations having successfully invoked his rights two weeks earlier; his waiver was voluntary and his statements were admissible; in any event, any error in admitting the statements was harmless in light of the minor role the statement played at trial and the overwhelming evidence that defendant had committed the bank robbery charged in the case; sentences imposed for the offense and upon the revocation of defendant's supervised release were not unreasonable.
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