D.Utah: Miranda violation led to unreasonable search of bag

Defendant’s statements were involuntary under Miranda and suppressed. That led to an unreasonable seizure of evidence in his bag. United States v. Archuleta, 981 F. Supp. 2d 1080 (D. Utah 2013):

The court finds Patane inapplicable here. In Patane, the defendant interrupted police who were trying to advise him of his Miranda rights, and volunteered the location of the physical evidence at issue. Archuleta’s comments were not only not this sort of unsolicited, spontaneous response, but were, as explained above, the only reasonable responses to calculated, coercive questioning which had the sole purpose of eliciting an incriminating response. Consequently, Pettigrew and the Fourth Amendment standards are more readily applicable.

It is evident under the logic of Pettigrew that Archuleta’s statements were not, in any meaningful way, voluntary. In Pettigrew, the court found that statements made in custody, half an hour apart, to different officers, without any attempt by police to obtain incriminating evidence, and without relying on any previous, unwarned statements for their foundation, were made voluntarily. Archuleta, on the other hand, made all of his statements in relative succession, to one officer who was explicitly trying to incriminate him, and each statement he made served as the predicate for successive questioning and searches. This, coupled with the court’s earlier analysis of the encounter between Archuleta and Officer Soakai, reveals that Archuleta’s statements were not the product of free and unconstrained choice, but rather, each answer painted Archuleta further and further into a corner from which there was no reasonable escape. The court, therefore, finds that Archuleta’s statements were not voluntary.

Lastly, because the statements were not voluntary, the seizure of the physical evidence violates the Fourth Amendment. Archuleta concedes that Officer Soakai had probable cause to stop him for a minor traffic violation. However, the encounter was not a consensual one, and Officer Soakai’s actions exceeded the permissible scope of the stop by questioning beyond the immediate reason for the stop without reasonable suspicion. As set forth above, Officer Soakai lacked any reasonable suspicion to continue detaining Archuleta after reviewing his criminal history and confirming that he was not a felon in possession of a firearm. Furthermore, as in Garcia, Officer Soakai relied solely on involuntary, unwarned statements to provide him with probable cause to search Archuleta and his bag. And, as in Garcia, because he improperly relied on these inadmissible statements, those searches were illegal, and the physical evidence seized as fruits of those searches should be suppressed.