United States v. Jonathan Rooney, No. 22-1647 (8th Cir. 2023)
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Defendant was charged with second-degree murder and tampering with evidence. A jury acquitted Defendant of the murder charge but found him guilty of voluntary manslaughter, a lesser included offense, and tampering with evidence. The district court sentenced Defendant to a total term of 300 months imprisonment. Defendant raised three issues on appeal: (1) the denial of his motion to suppress custodial statements; (2) the sufficiency of the evidence on the manslaughter and tampering counts; and (3) the procedural and substantive reasonableness of his sentence.
The Eighth Circuit affirmed. The court concluded that Defendant’s waiver of his Miranda rights was voluntary. Considering all the circumstances surrounding the ongoing search for the victim and conditions in which Defendant was held and questioned by law enforcement, the district court did not err in denying Defendant’s motion to suppress. Further, the court explained that a close review of the record establishes that a jury could have reasonably concluded that Defendant was guilty of manslaughter. The jury heard evidence that Defendant and the victim were the only two adults present at the cabin; that the victim’s blood was found both inside and outside the cabin; that Defendant had scratch marks on his face and upper body; and that Rooney and the victim were fighting in the time leading up to her death. There was sufficient evidence for the jury to find that Defendant put the victim’s body in the fire, which destroyed any evidence of the cause of death. Finally, the court found that Defendant’s claim that his sentence was substantively unreasonable is unavailing.
Court Description: [Erickson, Author, with Benton and Kelly, Circuit Judges] Criminal case - Criminal law and Sentencing. The two interrogations of defendant were not close enough in time to constitute a single, indistinct interrogation formally punctuated by Miranda warnings in the middle; thus the admissibility of defendant's post-Miranda statement is governed by Oregon v. Elstad, 470 U.S. 298 (1985) rather than Missouri v. Siebert, 542 U.S. 600 (2004); considering the totality of the circumstances, the district court did not err in determining that defendant's Miranda waiver was knowingly and voluntarily made and that certain of his statements to the police were admissible; the evidence was sufficient to support defendant's convictions for manslaughter and obstruction of justice through the destruction of evidence; the district court's statements at sentencing concerning defendant's state of mind when he committed the offenses were supported by the record and did not, in any event, serve as a principal basis for defendant's sentence; defendant's sentence was not substantively unreasonable. Judge Kelly, dissenting.
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