United States v. Jade LaRoche, No. 22-2969 (8th Cir. 2023)
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Defendant’s mother called local dispatch and said an officer needed to come by because her son was “acting up.” A Bureau of Indian Affairs Officer was dispatched to the home, learning on the way that Defendant had an active tribal arrest warrant. Defendant’s mother invited Defendant into the living room and told Defendant to join them. The officer told Defendant he was “going to have to take you because you got that warrant.” Defendant fled to the garage, pursued by the officer, where Defendant knocked the officer down and escaped. Defendant was charged with forcibly assaulting, resisting, opposing, impeding, intimidating, or interfering with a federal officer and inflicting bodily injury. The jury convicted him of the lesser included offense of forcible assault of a federal officer involving physical contact. The district court sentenced Defendant to 44 months’ imprisonment. He appealed, raising numerous evidentiary issues and challenging the assessment of a two-level sentencing increase.
The Eighth Circuit affirmed. The court explained that here, the amicable conversation -- dominated by Defendant-- occurred in his mother’s home, a non-custodial atmosphere. The officer testified he did not know what the warrant was based on. Defendant fled only after the officer later told him he would be arrested, confirming that Defendant initially believed or at least hoped that he could avoid immediate arrest. Further, the court explained that even if Defendant was in custody, follow-up questions to clarify ambiguity do not amount to “interrogation” unless “their point is to enhance the defendant’s guilt.” The court concluded the district court did not err in denying Defendant’s motion to suppress.
Court Description: [Loken, Author, with Erickson and Kobes, Circuit Judges] Criminal case - Criminal law and Sentencing. Considering the circumstances of the conversation defendant had with a law enforcement officer before he fled from the officer, the defendant was not in custody for purposes of determining whether his statements were admissible; the questions the officer asked concerning the existence of a warrant were asked to clarify the situation and give defendant an opportunity to provide an explanation that might avoid the need for an arrest; defendant's statements were made voluntarily, and the district court did not err in determining defendant's statements were admissible; the evidence was sufficient to support a guilty verdict on the charge of forcible assault of a federal officer involving physical contact in violation of 18 U.S.C. Sec. 111(a)(1); the district court did not err in admitting defendant's four prior convictions for assault of law enforcement officers, as the evidence went to intent; the district court did not err in imposing a two-level increase to defendant's offense level under Guidelines Sec. 2A2.4(b)(2) based on bodily injury to the officer.
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