United States v. Alfonzo Williams
2016 U.S. App. LEXIS 21621
| 9th Cir. | 2016Background
- Antonio Gilton was arrested for murder, read Miranda rights at interrogation, and unequivocally invoked his right to counsel.
- Hours later at county jail, a deputy asked Gilton whether he was affiliated with the Fillmore/Central Divisadero Playas (CDP) gang; Gilton replied in the affirmative.
- The deputy recorded Gilton’s answers on jail classification forms used to determine housing and "high risk" status; classification also relied on arrest records and police intelligence.
- Gilton was later federally indicted on RICO and murder-in-aid-of-racketeering charges for which gang membership is an element of the RICO count.
- The district court suppressed the jailhouse gang-affiliation statements under Miranda; the government appealed.
- The Ninth Circuit affirmed suppression, holding the booking-question exception did not apply because questions about gang affiliation were reasonably likely to elicit incriminating responses, and the public-safety exception was inapplicable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the deputy’s gang-affiliation question fell within Miranda’s interrogation prohibition after defendant invoked counsel | Gilton: asking about gang affiliation was interrogation reasonably likely to elicit incriminating answers and therefore required Miranda protections | Government: question was routine booking/administrative (housing) and not intended to elicit incriminating information; alternatively public-safety exception applied | Held: Question was reasonably likely to elicit incriminating responses given murder charges and gang-enhancement laws; booking exception did not apply |
| Whether the public-safety exception (Quarles) allows admission of the unadvised statement | Gilton: no immediate danger or exigency at time of question; no public-safety justification for foregoing warnings | Government: jail safety and inmate placement present public-safety concerns justifying the exception | Held: Public-safety exception not triggered—no immediate, objectively reasonable danger or exigency at the time of questioning |
| Whether the suppression should be limited to trial use (case-in-chief) or broader | Gilton: sought suppression of statements for use against him generally | Government: emphasized administrative use and routine practice; also argued limited purpose | Held: Court clarifies ruling only bars admission in government’s case-in-chief; does not preclude jail officials from making housing inquiries or using responses for classification purposes outside the prosecution’s principal case-in-chief |
| Standard for evaluating booking-question exception when answers may be incriminating | Gilton: where answers may incriminate, routine booking exception is disqualified; objective test whether police should have known question likely to elicit incriminating response | Government: booking questions are often routine and permissible; officer’s subjective administrative intent matters | Held: Applied objective Innis test—absence of gang charges does not eliminate objectively reasonable likelihood that gang-affiliation answers would be incriminating given applicable state and federal gang statutes and the murder charge |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (Miranda warnings & prohibition on custodial interrogation absent warnings)
- Rhode Island v. Innis, 446 U.S. 291 (definition of "interrogation" as police words/actions reasonably likely to elicit incriminating response)
- Pennsylvania v. Muniz, 496 U.S. 582 (plurality) (booking-questions exception for routine biographical data)
- New York v. Quarles, 467 U.S. 649 (public-safety exception to Miranda)
- United States v. Washington, 462 F.3d 1124 (9th Cir.) (booking-question issues re: gang moniker)
- United States v. Booth, 669 F.2d 1231 (9th Cir.) (objective test for interrogation under Innis)
- United States v. Henley, 984 F.2d 1040 (9th Cir.) (limits on booking exception when answers may incriminate)
- United States v. Gonzalez-Sandoval, 894 F.2d 1043 (9th Cir.) (citizenship/biographical questions not covered when answer likely incriminating)
- People v. Elizalde, 61 Cal.4th 523 (Cal.) (California gang statutes increase jeopardy for gang members; relevance to incriminating nature of affiliation)
- Maryland v. King, 133 S. Ct. 1958 (2013) (biometric/booking procedures and inmate safety rationale)