United States v. Fígaro-BenjamíN
392 F. Supp. 3d 280
United States District Court2019Background
- Defendant Maximiliano Fígaro-Benjamín was interviewed by HSI agents on January 29, 2019, the day of his arrest; Fígaro contends he was not given Miranda warnings before interrogation.
- Fígaro moved in limine two days before an August 20, 2019 trial, seeking to preclude his post-arrest statements under the Fifth Amendment (Miranda) as the proper remedy.
- The government contends agents did administer Miranda warnings and notes Fígaro received a video of the interview months earlier.
- The court treated the filing on substance as a motion to suppress (challenging admissibility based on constitutional grounds), not a true motion in limine.
- The court had set a deadline of June 25, 2018 for pretrial motions to suppress; Fígaro filed his motion nearly 14 months after that deadline.
- Applying Rule 12(c)(3) and relevant authority, the court denied the motion to suppress as untimely and left the August 20, 2019 trial date in place.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether post-arrest statements should be excluded for failure to receive Miranda warnings | Fígaro: HSI interrogated him without advising Miranda rights; statements must be suppressed | Government: Agents administered Miranda; video of the interview was produced months earlier | Court: Treated the filing as a motion to suppress but denied it as untimely under the court's pretrial-motion deadline |
| Whether a late-filed suppression motion may be considered when styled as a motion in limine | Fígaro: styled as motion in limine (implicitly seeking preclusion at trial) | Government: substance controls; late suppression motions are subject to Rule 12 and prior deadlines | Court: Substance governs; late motions to suppress may be denied for untimeliness |
| Proper remedy for alleged Fifth Amendment violation (suppression vs. other relief) | Fígaro: suppression of post-arrest statements is appropriate remedy | Government: disputes violation and emphasizes procedural deficiencies in motion timing | Court: did not reach merits; denied on procedural (timeliness) grounds |
| Effect of Rule 12(c)(3) on untimely suppression motions | Fígaro: did not meaningfully contest Rule 12 timing in merits filing | Government: relied on Rule 12 and cases supporting denial of late motions | Court: applied Rule 12(c)(3) and precedent to deny the motion as untimely |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (establishes required warnings and exclusionary remedy for custodial interrogation)
- United States v. Hurst, 228 F.3d 751 (6th Cir. 2000) (distinguishing suppression motions from evidentiary motions in limine)
- United States v. Mangine, 302 F.3d 819 (8th Cir. 2002) (substance of filing controls; late suppression motions disguised as motions in limine are improper)
- United States v. Sweeney, 887 F.3d 529 (1st Cir. 2018) (district court need not review untimely suppression motions under Rule 12(c)(3))
- United States v. Tineo-González, 893 F.3d 64 (1st Cir. 2018) (affirming denial of suppression motion filed after explicit pretrial deadline)
- United States v. Levasseur, 699 F. Supp. 995 (D. Mass. 1988) (denying untimely suppression motion where underlying information was known before the deadline)
- United States v. Trancheff, 633 F.3d 696 (8th Cir. 2011) (affirming denial of untimely motion to suppress evidence)