United States v. Justin Treanton, No. 22-1476 (8th Cir. 2023)Annotate this Case
Defendant pleaded guilty to two child pornography offenses. The district court sentenced him to 600 months’ imprisonment. On appeal, Defendant challenges the district court’s denial of his motion to suppress evidence, and the sentence imposed. Defendant argued that the district court erred by denying his motion to suppress statements from his interview.
The Eighth Circuit affirmed the judgment, concluding there was no reversible error. The court explained that circumstances do not establish that Defendant was in custody during the interview. Agents did not physically restrain him in the vehicle. Only two agents questioned him, and they repeatedly told Defendant that he was not under arrest and was free to leave. The agents were not deceptive or threatening, and Defendant voluntarily answered their questions. The court reasoned with the district court that a reasonable person in Defendant’s position would have believed that he was free to terminate the interview if he wished. Considering the totality of the circumstances, the court concluded Defendant was not in custody for purposes of Miranda, and that the district court properly declined to suppress incriminating statements made during the interview before agents informed Defendant that he would be arrested.
Further, the court held that the district court properly considered the factors under 18 U.S.C. Section 3553(a), and elected to impose Defendant’s advisory guideline sentence. The court saw no compelling circumstances in support of a shorter sentence that demonstrate an abuse of the district court’s discretion.