United States v. Cornelius Mitchell, 523 F. App'x 411

Mitchell was arrested following a search of his apartment based on a warrant and ongoing drug investigation.
An informant had previously purchased crack from Mitchell, establishing probable cause a month earlier.
Drugs and a firearm were found during the apartment search after Mitchell’s arrest.
Mitchell initially invoked right to counsel but later spoke to officers and provided statements about ownership of the drugs and gun.
Mitchell moved to suppress both physical evidence and statements as fruits of unlawful arrest and unconstitutional interrogation; he pleaded guilty while preserving appeal on these rulings.
The district court denied the suppression motions; the appellate review was limited to the suppression issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were the physical evidence and confession fruits of an unlawful arrest?	Mitchell argues suppression of evidence and confession as fruits of unlawful arrest.	Mitchell contends arrest was illegal or unlawfully motivated to seize evidence.	No; arrest based on prior drug buy provided probable cause; evidence not fruit of unlawful arrest.
Were the statements obtained in violation of Miranda or rights to counsel admissible?	Mitchell contends Miranda/Right to counsel were violated by interrogation.	Mitchell argues statements should be suppressed for failure to respect rights.	No; Mitchell voluntarily reinitiated conversation after invocation, making statements admissible.
Was Mitchell's delay in appearing before a magistrate within permissible limits?	Delay to judicial appearance violated his rights.	Delay was reasonable under Rule 5 and due process.	Yes; appearance within 48 hours, delay within constitutional and procedural tolerances.

United States v. Watson, 423 U.S. 411 (U.S. 1976) (probable cause supports arrest for drug offenses)
Carrillo, 269 F.3d 761 (7th Cir. 2001) (probable cause sufficient for arrest and search justification)
Navarro, 90 F.3d 1245 (7th Cir. 1996) (temporal proximity of events sustaining arrest rationale)
Mitten, 592 F.3d 767 (7th Cir. 2010) (continued probable-cause considerations post-arrest)
Forman v. Richmond Police Dept., 104 F.3d 950 (7th Cir. 1997) (time-to-appearance considerations under 5(a))
Kirkland, 567 F.3d 316 (7th Cir. 2009) (prompt initial appearance standards and waiver implications)
Corley v. United States, 556 U.S. 303 (U.S. 2009) (reinitiated questioning and waiver after initial rights invocation)
Davis v. United States, 512 U.S. 452 (U.S. 1994) (reinitiation of questioning after rights advised can be admissible)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (ongoing interrogation after invoking counsel considerations)
United States v. Morrison, 594 F.3d 626 (8th Cir. 2010) (post-arrest conduct and evidence temporality considerations)
Riverside v. McLaughlin, 500 U.S. 44 (U.S. 1991) (speedy probable cause determinations and appearance timing)