United States v. Dhawndric McDowell, 687 F.3d 904

McDowell, a Chicago Police Department informant, also sold cocaine for a Mexican cartel; DEA used a supplier "Jose" for a sting.
Jose arranged ten kilograms of cocaine delivery to McDowell; McDowell was arrested at the drop point in Chicago.
After arrest, McDowell signed a written Rule 5(a) waiver consenting to forgo prompt presentment for up to 72 hours and spent the night in jail.
The next morning he signed a Miranda waiver and confessed during a 2-hour interview about his cocaine-trafficking activities.
He was presented before a magistrate about 19 hours after arrest; indictment followed for conspiracy and attempted possession with intent to distribute.
McDowell argued suppression under McNabb-Mallory § 3501(c), production of Jose, and a corroboration jury instruction; district court rejected all three.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prompt presentment and McNabb-Mallory viability	McDowell: delay violated Rule 5(a) and McNabb-Mallory; § 3501(c) governs admissibility.	McDowell waived prompt presentment; waiver eliminates McNabb-Mallory concerns.	Waiver displaced McNabb-Mallory concerns; confession admissible.
Production of cooperating source Jose	Jose’s testimony could be necessary for due defense; informant identity should be disclosed.	Roviaro privilege applies; Jose’s disclosure not warranted given transactional role and strength of evidence.	District court did not abuse discretion; production not required.
Corroboration instruction requirement	Jury should be given corroboration instruction for confessed statements.	No corroboration instruction required; standard burden-shift instructions suffice.	No abuse of discretion; corroboration instruction denied.

McNabb v. United States, 318 U.S. 332 (U.S. 1943) (prompt-presentment exclusionary rule foundational)
Mallory v. United States, 354 U.S. 449 (U.S. 1957) (continued McNabb-Mallory rule)
Corley v. United States, 556 U.S. 303 (U.S. 2009) (statutory modification of McNabb-Mallory via § 3501)
United States v. Kirkland, 567 F.3d 316 (7th Cir. 2009) (McNabb-Mallory framework with Corley considerations)
United States v. Mansoori, 304 F.3d 635 (7th Cir. 2002) (multifactor McNabb-Mallory assessment factors)
United States v. Gaines, 555 F.2d 618 (7th Cir. 1977) (McNabb-Mallory factors in assessing delay)
United States v. Spruill, 296 F.3d 580 (7th Cir. 2002) (additional McNabb-Mallory considerations)
Howard v. United States, 179 F.3d 539 (7th Cir. 1999) (courts may omit specific corroboration instruction; standard instructions often suffice)
Opper v. United States, 348 U.S. 84 (U.S. 1954) (corroboration requirement governing sufficiency of confession evidence)
Dalhouse v. United States, 534 F.3d 803 (7th Cir. 2008) (corroboration in confession cases)
Jackson v. United States, 103 F.3d 561 (7th Cir. 1996) (corroboration principles in conviction validation)
Sawyer v. United States, 558 F.3d 705 (7th Cir. 2009) (duress framework and immediacy requirements)