United States v. Chester Ray Slaughter
708 F.3d 1208
| 11th Cir. | 2013Background
- Slaughter, a registered sex offender, was charged with §2422(b) and §2260A.
- He used Craigslist Casual Encounters to contact an undercover FBI agent posing as a minor.
- He engaged in emails, expressed a daddy-daughter fantasy, and planned a hotel meeting.
- Officers arrested him at the hotel room without warrants; he later signed consent searches.
- Miranda warnings were given at the station; he waived rights and provided a videotaped interview.
- District court denied suppression and admitted the statement under Harris; trial used a redacted interview.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Suppression of custodial statement under Harris | Slaughter argues the Fourth Amendment violation tainted the statement | Slaughter argues Harris should suppress the statement | Statement admissible under Harris (no suppression) |
| Severance of counts 1 and 2 | Counts should be tried separately to avoid prejudice | Severance not required; joinder proper | District court did not abuse discretion in denying severance |
| §2260A requires an actual minor | Conviction requires contact with an actual minor | §2260A can apply where §2422(b) involves an attempted enticement | §2260A predicated on §2422(b) does not require an actual minor; conviction sustained |
Key Cases Cited
- United States v. Harris, 495 U.S. 14 (U.S. 1990) (exclusionary rule and Miranda-waived statements admissible after lawful arrest)
- United States v. Root, 296 F.3d 1222 (11th Cir. 2002) (enticing a minor without actual minor still a §2422(b) violation)
- United States v. Zuniga-Arteaga, 681 F.3d 1220 (11th Cir. 2012) (interpretation of §2260A; statute-within-context analysis)
- United States v. Daniels, 685 F.3d 1237 (11th Cir. 2012) (protecting minors; application of §2260A practitioner-focused rationale)
- United States v. Walser, 3 F.3d 380 (11th Cir. 1993) (severance standard; need for compelling prejudice)