United States v. Haak, 884 F.3d 400

John Haak voluntarily went to a police station on March 4, 2015 for a non-custodial interview about the fentanyl-laced heroin overdose death of James Forness; the interview was video-recorded, lasted ~30+ minutes, and Haak left afterward.
Detective Sgt. Glenn Zawierucha (of a police–DEA task force) advised Haak of Miranda-style rights (including right to silence, counsel, and to leave) and repeatedly told him police were not arresting him that day.
Early in the interview Haak made inculpatory admissions that he had supplied heroin to Forness and acknowledged texts warning ‘‘be careful’’ because of possible fentanyl.
During the interview Zawierucha urged Haak to cooperate, used a ‘‘team’’ analogy and told him he was "not looking to come after" Haak but warned that if Haak remained silent "the weight of the federal government is gonna come down on you." He also said Haak would likely not be pulled into the larger investigation if he helped.
After the interview Haak arranged controlled buys that led to the arrest of a supplier; Haak was later charged federally with distribution of fentanyl resulting in death and moved to suppress his March 4 statements as involuntary.
The district court suppressed the statements, concluding the detective’s statements amounted to a false promise of immunity that overbore Haak’s will; the government appealed.

Issue	Plaintiff's Argument (Haak)	Defendant's Argument (U.S.)	Held
Whether Zawierucha’s statements amounted to a promise of immunity that coerced Haak’s statements	The detective’s assurances ("not looking to come after you," "join the team," "you'll save yourself a world of hurt") implied a clear promise of non‑prosecution in exchange for cooperation, rendering statements involuntary	The words, in context, were at most assurances of honesty and temporary forbearance of arrest or vague promises of leniency, not a promise of immunity; Haak had already admitted involvement before those statements	Reversed: no clear, unmistakable promise of immunity; statements voluntary under the totality of circumstances
Whether any coercive police conduct overbore Haak’s will (voluntariness test)	The implied immunity promise was the critical factor that induced Haak to speak, so his will was overborne	Even if some statements were ambiguous, the totality of circumstances (non‑custodial setting, Miranda warnings, brief interview, Haak’s maturity and earlier admissions) show voluntariness	Reversed: totality favors voluntariness; no coercion established

Miranda v. Arizona, [citation="384 U.S. 436"] (establishing Miranda warnings requirement)
Schneckloth v. Bustamonte, [citation="412 U.S. 218"] (voluntariness standard for confessions)
Colorado v. Connelly, [citation="479 U.S. 157"] (coercive police activity as predicate for involuntariness)
Dickerson v. United States, [citation="530 U.S. 428"] (constitutional basis for voluntariness rules)
United States v. Ruggles, [citation="70 F.3d 262"] (material misrepresentations and voluntariness)
United States v. Jaswal, [citation="47 F.3d 539"] (vague promises of leniency generally not coercive)
United States v. Gaines, [citation="295 F.3d 293"] (same; promises of leniency require more to be coercive)
United States v. Anderson, [citation="929 F.2d 96"] (false or misleading police statements do not automatically render confession involuntary)
United States v. Braxton, [citation="112 F.3d 777"] (truthful warnings about penalties are not coercion)
United States v. Bohannon, [citation="824 F.3d 242"] (de novo review where facts undisputed)