United States v. Valquier, No. 18-1636 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction for conspiring to distribute methamphetamine. Even assuming that it was error to allow an officer to testify regarding defendant's pre-Miranda statements and actions, the admission of the testimony did not violate defendant's substantial rights. In this case, the officer testified that defendant gave a false explanation for his presence and hung his head in an apparent show of defeat at having been caught. The court rejected defendant's alleged Confrontation Clause violations, because any violation would not have posed a reasonable probability of altering the outcome of the trial and were not plain error.
Court Description: Melloy, Author, with Colloton and Shepherd, Circuit Judges] Criminal Case - conviction. Valquier arrived at house during a search and gave his name to an officer and "kind of hung his head" in response to an officer's question prior to receiving Miranda warning. District court did not plainly err in failing to suppress Valquier's pre-Miranda statements and actions; although it was error for officer to testify regarding Valquier's statement and action because he was in custody and being interrogated, the error did not affect substantial rights in light of other evidence at trial. Confrontation Clause challenges posed no reasonable probability of altering the outcome of the trial and were not plain error.
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