United States v. Ramon Simpson, No. 21-2463 (8th Cir. 2022)
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Defendant was convicted of kidnapping resulting in death and conspiracy to commit kidnapping. On appeal, Defendant challenges several rulings of the district court* and the sufficiency of the evidence in support of the convictions.
The Eighth Circuit affirmed. Defendant’s first argument on appeal is that the district court erred by denying his motion to suppress statements from the interviews on November 8 and 21, 2018. He contends that investigators subjected him to custodial interrogations without advising him of his rights under Miranda v. Arizona. The court concluded that there was no custodial interrogation of Defendant on November 8. Defendant responded to the FBI agent’s request for a conversation and agreed to let the agent come to his house for the meeting. The agent did not display a weapon or restrain Defendant in any way. The agent was dressed in plain clothes and allowed Defendant’s wife to sit nearby for the interview. Further, the court held that there is no indication that Defendant is particularly susceptible to undue influence: he is an adult of average intelligence who has earned an associate’s degree and is familiar with the protections afforded by the legal system due to an extensive criminal history.
Moreover, the court held that the district court did not abuse its discretion by concluding that the probative value of the evidence was not substantially outweighed by a danger of unfair prejudice. Further, the court concluded that there was no error in declining to instruct the jury that the government must prove that Defendant knew in advance that death would result from the kidnapping.
Court Description: [Colloton, Author, with Wollman and Shepherd, Circuit Judges] Criminal case - Criminal law. Defendant was not in custody at the time he made incriminating statements; the statements were voluntary, and they were admissible; the district court did not abuse its discretion by admitting photos and a video of the crime scene, including the body of the victim; the photos corroborated the testimony of the officers regarding the location and state of the victim's body and tended to show the cause of death; the district court did not err in instructing the jury on liability for aiding and abetting a kidnapping resulting death or in rejecting defendant's proposed instruction requiring the government to prove that defendant knew in advance that death would result from the victim's kidnapping; the evidence was sufficient to support defendant's convictions for kidnapping resulting in death and conspiracy to commit kidnapping.
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