United States v. Figueroa-Serrano, No. 19-2635 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a gun seized without a warrant during a traffic stop and his subsequent statements to law enforcement. The court held that, based on the information the officers knew at the moment they seized the gun, they had probable cause to believe defendant possessed the weapon.
The court also held that, although the district court erred by failing to suppress defendant's statements, the error was harmless in light of the overwhelming evidence of defendant's guilt. The court further held that the district court did not err by deciding that defendant voluntarily and knowingly waived his rights when he agreed to speak with the officers and then to the special agent.
Court Description: [Kelly, Author, with Erickson and Stras, Circuit Judges] Criminal case - Criminal law. Based on the information officers knew at the moment they seized a handgun in defendant's vehicle, they had probable cause to believe that he possessed the weapon in violation of 18 U.S.C. Sec. 922(g)(3), which prohibits the possession of a firearm by an unlawful user of a controlled substance, and the seizure was lawful; because police subjected defendant to custodial interrogation without giving him Miranda warnings, the district court erred by failing to suppress the un-warned statements; however, the error was harmless in light of the overwhelming independent evidence of defendant's guilt; post-Miranda warnings, defendant knowingly and voluntarily gave up his rights when he consented to speak with the officers, and his statements were admissible; further, defendant voluntarily waived his rights when he agreed to speak on the phone to an Department of Homeland Security special agent about the gun and his immigration status.
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