United States v. Outland, 2021 WL 1399280 (7th Cir 2021)
Officers arrested Jeremy Outland for selling heroin. As officers were driving Outland to the local Drug Enforcement Agency office for questioning, an officer saw that Outland was collapsed in the back seat with white powder on his face and jacket. Outland claimed he ate 3.5 grams of heroin that he’d hidden during the arrest. The officers rushed Outland to a nearby emergency room.
Outland was unresponsive upon arrival at 1044. After several interventions by doctors, Outland temporarily regained consciousness at 1051, then lost consciousness at 1110 and again at 1120. Doctors placed Outland on a continuous intravenous drip at 1225 and prepared to move him to the intensive care unit.
At 1300, a detective arrived at the hospital to speak with Outland. The detective read a Miranda warning and Outland agreed to talk. During the following 45 minutes, Outland made several incriminating statements about his heroin business. Outland later asked the trial court to suppress his statements, claiming he “was so intoxicated as to render his statement involuntary” and that “he was unable to voluntarily and knowingly waive his Miranda rights based upon a long list of medications he was under at the time.”
The trial judge noted Outland claimed to not remember waiving his rights and his testimony that he was under the influence of drugs during the interview. The court also cited the detective’s “contrary impressions of Outland’s mental state—that Outland was coherent, had requested to speak with law enforcement, and, despite appearing under the influence of heroin, never lost consciousness during the interview.” The trial court denied Outland’s motion to suppress. However, the judge did not determine whether Outland knowingly and intelligently waived his Miranda rights at the outset of the interview.
The appellate court remanded the case back to the trial court for a specific determination on the validity of Outland’s Miranda rights waiver.
When a defendant seeks suppression of statements made during custodial interrogation, the court must answer two related, but distinct, questions. First, whether officers informed the defendant of Miranda rights and then validly waived the Miranda rights, and second, whether the defendant’s statements, in the totality of the circumstances of the interview as a whole, were voluntary.
The court of appeals cited the circumstances of the interview: Outland “overdosed on heroin, awoke in an emergency room, and lapsed in and out of consciousness as the medical team administered several rounds of drugs.” The interrogation followed less than two hours later. In those circumstances, the lack of a trial court finding as to whether Outland knowingly and intelligently waived his Miranda rights was a material omission. The appellate court remanded the case back to the trial court for a specific determination on the validity of Outland’s Miranda rights waiver.
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