United States v. Tapia-Rodriguez, No. 18-3751 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to conspiracy to distribute and possess with intent to distribute 500 grams or more of methamphetamine. The court held that the district court did not err in denying defendant's motion to suppress statements made when police officers, about to conduct a search to which his roommate had consented, asked defendant "if he lived in the house and which bedroom was his."
In this case, neither of the two questions at issue constituted interrogation that required Miranda warnings because a request for routine information necessary for basic identification purposes is not interrogation, even if that information later turns out to be incriminating. Furthermore, the officer's follow up question asking defendant to identify his bedroom, although it presents a closer question, was permissible because the officers needed to determine whether defendant occupied the bedroom and, if so, whether he consented to the search. Therefore, the district court properly denied the motion to suppress.
Court Description: [Loken, Author, with Benton and Kelly, Circuit Judges] Criminal case - Criminal law. Asking defendant his name and whether he lived in the apartment were requests for basic identification information and could be asked without giving defendant his Miranda warnings; asking defendant to identify his bedroom in the apartment before providing Miranda warnings presents a closer question, but was permissible because the police had a legitimate need for the information to ensure they were conducting a lawful consensual search based on defendant's roommate's consent to a search of the apartment; the officers only asked questions that were reasonably related to obtaining defendant's consent to search and did not ask him anything intended to solicit an incriminating response. Judge Kelly, dissenting.
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