United States v. Allen Murdock
667 F.3d 1302
D.C. Cir.2012Background
- Murdeock is accused of first-degree murder, firearm possession during a crime of violence, and conspiracy; interrogation occurred after he was transferred from jail to police custody.
- Detective Whalen questioned Murdock in a small windowless room after advising him his conversation was recorded; interrogation followed Miranda-style rights and a read of his rights.
- Government concedes the interrogation violated Miranda by failing to scrupulously honor right to cut off questioning.
- District court suppressed Murdock’s statements as involuntary under Miranda, concluding the two refusals to talk were ignored and he likely faced charges.
- Government contends the statements are admissible for impeachment if voluntary under Mincey/Harris framework; district court’s voluntariness findings are challenged.
- Appellate court reverses, holding Miranda-violating statements may be used for impeachment if voluntary under the general voluntariness inquiry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Miranda-violating statements admissible for impeachment? | United States argues admissible for impeachment. | Murdock argues not admissible since involuntary. | Yes, admissible for impeachment. |
| Was the district court correct that the statements were involuntary? | United States contends totality shows voluntariness. | Murdock argues factors show coercion and overbore will. | District court erred; statements voluntary under totality. |
Key Cases Cited
- Harris v. New York, 401 U.S. 222 (U.S. Supreme Court 1971) (impeachment use of Miranda-violating statements)
- Oregon v. Hass, 420 U.S. 714 (U.S. Supreme Court 1975) (impeachment admissibility balanced against coercive conduct)
- Mincey v. Arizona, 437 U.S. 385 (U.S. Supreme Court 1978) (voluntariness standard for statements)
- Lego v. Twomey, 404 U.S. 477 (U.S. Supreme Court 1972) (burden to show voluntariness of statements)
- Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. Supreme Court 1973) (factors of interrogation and voluntariness)
- Parsad v. Greiner, 337 F.3d 175 (2d Cir. 2003) (mere Miranda violation does not automatically imply coercion)
- Collazo v. Estelle, 940 F.2d 411 (9th Cir. 1991) (menacing content of interrogation as key factor)