United States v. Roberts, No. 19-3249 (8th Cir. 2020)
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Following a shooting, police went to Roberts’s apartment to execute a search warrant on the residence and a Durango vehicle. Officers found firearms. An officer stated Roberts was not under arrest. Roberts admitted he brought the guns into the residence from the Durango, where “Mike” had left them. The officers noted possible federal firearm charges because they knew Roberts was a felon. The officers did not arrest Roberts, but read his Miranda rights, despite Roberts saying “you don’t have to.” Officers asked if Roberts wanted to continue to talk. Roberts replied, “Not really,” but continued the interview. He admitted driving a man to the crime scene on the night of the shooting in the Durango. Roberts was arrested hours later. Roberts entered a conditional guilty plea to being a felon in possession of a firearm, reserving the right to appeal the denial of his motion to suppress.
The Eighth Circuit affirmed, finding that the affidavit supplied with the search warrant application gave the judge probable cause to believe that Roberts drove the vehicle associated with a shooting on the night of the shooting and that evidence of the crime would be found in the truck or his residence. Roberts’s incriminating statements before receiving Miranda warnings were admissible; he was not in custody and the statements were voluntary. Roberts's prior Illinois and Iowa convictions were controlled substance offenses for purposes of sentencing under Guidelines 4B1.1(a).
Court Description: [Loken, Author, with Grasz, Circuit Judge, and Clark, District Judge] Criminal case - Criminal law and sentencing. The affidavit supplied with the search warrant application gave the issuing judge probable cause to believe that defendant drove the pickup truck associated with a shooting on the night of the shooting and that evidence of the crime would be found in the truck or defendant's residence; based on the facts presented, incriminating statements defendant made prior to receiving Miranda warnings were admissible as he was not in custody at the time he made them; the statements were voluntary and were not the products of improper threats or promises which overcame defendant's will; defendant's prior Illinois and Iowa convictions were controlled substance offenses for purposes of sentencing under Guidelines Sec. 4B1.1(a).
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