United States v. Charles James Jones, 2016 U.S. App. LEXIS 21515

Charles Jones and Shalonda Clark, cohabiting on the White Earth Indian Reservation, were methamphetamine addicts; their home caught fire in December 2013 while both were intoxicated; Clark died on the living-room couch.
After the fire, Jones went to a neighbor's house; officers found him singed and sooty; he made several statements including "I started it," and later "You finally fucking got me" and "I hope I get the max."
Jones was arrested, charged, tried by jury, convicted of second-degree murder, and sentenced to 324 months; he appealed several evidentiary rulings and the sentencing enhancement for a vulnerable victim.
Defense expert fire investigator R. Paul Bieber was disclosed but the district court limited his testimony to opinions actually set out in the final Rule 16 disclosure, excluding testimony about alleged cognitive bias and alternative causes not detailed in disclosures.
Jones moved to suppress several custodial and pre-custodial statements as Miranda violations and as involuntary due to intoxication; the district court admitted most statements under the public-safety exception and found statements voluntary.
At sentencing the district court applied a two-level vulnerable-victim enhancement under U.S.S.G. §3A1.1(b)(1); the court found Jones knew or should have known Clark was vulnerable because she was asleep and impaired from drugs.

Issue	Jones' Argument	Government's Argument	Held
Exclusion of expert testimony/photographs under Rule 16(b)(1)(C)	District court erred by limiting Bieber's testimony and excluding photos rebutting prosecution expert	Defense failed to disclose opinions and bases in required detail; court may exclude undisclosed expert evidence	Affirmed — district court did not abuse discretion; exclusion appropriate for inadequate disclosures
Suppression of pre-discovery/fire-scene statements to officer Sweere	Statements were custodial and should be suppressed under Miranda; intoxication rendered them involuntary	Many answers fell within public-safety exception; statements were voluntary despite intoxication	Affirmed — public-safety exception applied; court did not clearly err on voluntariness
Suppression of spontaneous remarks after handcuffing and during transport	Post-handcuff and transport remarks should be suppressed as product of custody/interrogation	Some remarks were spontaneous or non-responsive; clarification questions not interrogation	Affirmed — spontaneous remarks admissible; clarification not interrogation
Vulnerable-victim sentencing enhancement	Enhancement improper because admissions were suppressed, expert could have shown victim not vulnerable, and Jones was too intoxicated to know her condition	Evidence showed Clark asleep/impaired; Jones supplied drugs and was coherent enough to know her vulnerability	Affirmed — enhancement appropriately applied; factual finding not clearly erroneous

United States v. Coutentos, 651 F.3d 809 (8th Cir. 2011) (abuse-of-discretion standard for expert‑testimony discovery rulings)
United States v. Holmes, 670 F.3d 586 (4th Cir. 2012) (disclosure requirements under Rule 16 and exclusion of undisclosed expert opinions)
Rhode Island v. Innis, 446 U.S. 291 (1980) (definition of interrogation and the test for words or conduct reasonably likely to elicit an incriminating response)
United States v. Everman, 528 F.3d 570 (8th Cir. 2008) (public‑safety exception to Miranda)
United States v. Casal, 915 F.2d 1225 (8th Cir. 1990) (intoxication does not automatically render confession involuntary; focus on whether will was overborne)
United States v. Chipps, 410 F.3d 438 (8th Cir. 2005) (spontaneous statements and officer clarification distinguishable from interrogation)
United States v. Ferrer-Montoya, 483 F.3d 565 (8th Cir. 2007) (suspect must clearly and consistently invoke right to remain silent to terminate questioning)
United States v. Betone, 636 F.3d 384 (8th Cir. 2011) (standard of review for sentencing guidelines interpretations and clear‑error review of factual findings)