United States v. Brian Lanier Turner, 20-13450

Turner was arrested on state drug charges in Blount County, Alabama; five state charges were pending and attorney John Floyd represented him.
On September 20, 2018, two local investigators and DEA Agent Domingo Gonzalez visited Turner at his home seeking cooperation in a DEA investigation into supplier Jose Martinez; Turner admitted purchasing large quantities of methamphetamine and cocaine.
Two of the state offenses rested on the same conduct later charged in the federal indictment; in November 2018 a federal grand jury indicted Turner for conspiracy to possess/distribute methamphetamine and cocaine and for using a telephone to facilitate a felony.
Turner moved to suppress his September 20 statements, arguing Miranda/Fifth Amendment and that the Sixth Amendment barred interrogation without his state-court counsel present.
The district court found Turner was not in custody (so no Miranda violation) and that the Sixth Amendment right to counsel had attached only as to the state charges and did not prohibit questioning about distinct federal offenses; the statements were admitted and Turner was convicted on Count One.
On appeal Turner contended the absence of his state-court counsel at the DEA interview violated his Sixth Amendment rights; the Eleventh Circuit affirmed, applying the offense-specific rule and dual-sovereignty reasoning and rejecting an exception based on one sovereign acting as a "tool" of another.

Issue	Turner’s Argument	Government’s Argument	Held
Whether the Sixth Amendment barred questioning by federal agents because Turner was represented on related state charges	Turner: right to counsel had attached for overlapping conduct; questioning concerned same conduct and required counsel	Gov: Sixth Amendment is offense-specific; only state charges had attached and federal questioning concerned distinct sovereign offense	The right had attached only to the state charges; federal questioning did not violate the Sixth Amendment
Whether the dual-sovereignty/doctrine-of-"tool" exception applies (i.e., federal govt. acted as a tool of the state)	Turner: coordination and joint interviews show federal agents acted as a tool of state, so sovereignty distinction should collapse	Gov: cooperation does not show domination or control; both sovereigns acted independently	No exception applies; mere cooperation insufficient to show one sovereign dominated the other
Whether statements required suppression under Miranda/Fifth Amendment	Turner: no Miranda warnings were given, so statements should be suppressed	Gov: Turner was not in custody during the interview, so Miranda did not apply	District court correctly found Turner not in custody; Miranda does not bar the statements

McNeil v. Wisconsin, 501 U.S. 171 (1991) (right to counsel attaches once prosecution has been initiated; offense-specific rule)
Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings)
Texas v. Cobb, 532 U.S. 162 (2001) (offense-specific Sixth Amendment analysis and Blockburger test context)
Blockburger v. United States, 284 U.S. 299 (1932) (double-jeopardy/identity-of-offense test used to compare offenses)
Bartkus v. Illinois, 359 U.S. 121 (1959) (discusses dual sovereignty and the potential "tool" exception)
United States v. Burgest, 519 F.3d 1307 (11th Cir. 2008) (offense-specific right and separate-sovereign analysis)
United States v. Baptista-Rodriguez, 17 F.3d 1354 (11th Cir. 1994) (discusses showing required to prove sovereign domination/control)