United States v. Guzman
2012 WL 3038542
E.D.N.Y2012Background
- Guzman charged in a Juvenile Information with multiple violent offenses tied to MS-13, later transferred for adult prosecution.
- Court granted transfer to district court for prosecution as an adult after a 2010 evidentiary hearing.
- Guzman moved to suppress post-arrest statements, arguing lack of knowing and voluntary Miranda waiver due to interrogation circumstances and parental-notification failure under the JDA.
- Judge declined per se suppression for JDA parental-notification violation, adopting a totality-of-the-circumstances approach, aligned with the Sixth Circuit.
- Court found Guzman’s Miranda waiver knowing, intelligent, and voluntary under the totality framework, despite not notifying his mother at arrest.
- Alternative Ninth Circuit analysis considered; court concluded the violation was harmless beyond a reasonable doubt and denied suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does JDA parental notification failure require suppression? | Guzman argues notification failure taints statements. | Guzman contends automatic suppression is required by JDA. | No per se suppression; analysis under totality of circumstances. |
| Is Guzman’s Miranda waiver valid under totality of circumstances given juvenile status and notification gaps? | Waiver invalid due to coercion and lack of parental contact. | Waiver valid; officers properly administered warnings and elicited voluntary responses. | Waiver found knowing, voluntary, and intelligent. |
| Should the court adopt Sixth Circuit approach over Ninth Circuit for JDA § 5033 violations? | Ninth Circuit approach should govern due process considerations. | Sixth Circuit framework is persuasive and adopted. | Court adopts Sixth Circuit standard; analyzes JDA violation as a factor in totality-of-circumstances. |
| Was the JDA parental-notification violation prejudicial under Ninth Circuit harmlessness framework? | Violation prejudices defendant by tainting waiver. | Violation was harmless beyond a reasonable doubt. | Violation deemed harmless; suppression denied under alternative analysis. |
Key Cases Cited
- Fare v. Michael C., 442 U.S. 707 (U.S. 1979) (special considerations for juvenile interrogations; waiver requires awareness of rights and consequences)
- In re Gault, 387 U.S. 1 (U.S. 1967) (juvenile rights; need special care in waivers and counsel participation)
- North Carolina v. Butler, 441 U.S. 369 (U.S. 1979) (totality-of-the-circumstances approach to evaluating waiver)
- Colorado v. Spring, 479 U.S. 564 (U.S. 1987) (reflects that knowing/voluntary waiver need not be perfect understanding of every consequence)
- United States v. Doe, 226 F.3d 672 (6th Cir. 2000) (Sixth Circuit: JDA § 5033 violation does not require per se suppression; focus on voluntariness)
- United States v. Juvenile Male, 595 F.3d 885 (9th Cir. 2010) (due process and harmlessness framework for § 5033 violations)
- D.L. v. United States, 453 F.3d 1115 (9th Cir. 2006) (harmlessness/prejudice considerations in juvenile statements)
- Wendy G. v. United States, 255 F.3d 761 (9th Cir. 2001) (prejudice and remedy considerations in juvenile cases)
- Sanchez-Llamas v. Oregon, 547 U.S. 331 (U.S. 2006) (exclusionary rule context; caution in applying to statutory violations)
- Donovan v. United States, 429 U.S. 413 (U.S. 1977) (statutory violations and suppression remedies depend on statute text)
- Clenney, 631 F.3d 658 (4th Cir. 2011) (statutory vs constitutional violation; suppression depends on text)