Sunday, May 17, 2009

United States v. Carter, 884 F.2d 368 (8th Cir. 1989)

Facts

Postal inspectors placed marked bills and a bearer check in mail trays and tracked the stolen checks to Carter.  Carter was interviewed in the bank president’s office by the inspectors and bank security manager for 1.5 hours.  After obtaining incriminating statements, Carter was informed of his Miranda rights and he signed a handwritten admission of guilt.

Procedural History

Carter moved to suppress his statements and the bait money and the district court granted the motion, finding the interrogation occurred in a custodial setting.

Issue(s)

Did the district court err in suppressing the evidence on the grounds that the interrogation was in a custodial setting and that Carter’s statements were not voluntary?

Holding(s)

No.

Reasoning/Analysis

The Court found that in evaluating the factors of Carter’s interrogation (bank president’s office, isolation from others, not free to leave, and the length of interrogation) we discern no clear error in the conclusion that Carter could have reasonably believed the interrogation was custodial in nature.

Judgment/Outcome

The Court affirmed the judgment of the district court.

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