United States v. Hayes, 4:15-cr-00033

Defendant Aronae (Aaronae) Smith was found by a magistrate judge to have violated probation by associating with Isaiah McClain, a convicted felon; magistrate sentenced her to two additional years of probation.
Smith appealed, raising three principal challenges: (1) her custodial statements should have been excluded for inadequate Miranda warnings; (2) the government failed to prove she knew McClain was a felon and had notice of the no-contact probation condition; and (3) the no-contact order unlawfully forbids maintaining contact with McClain.
The Ninth Circuit remanded the appeal to the district court for further proceedings; district court reviews factual findings for clear error and legal conclusions de novo, and may affirm on any record-supported basis.
Record shows an officer informed Smith of Miranda rights (right to remain silent, right to counsel, appointed counsel if indigent), Smith acknowledged understanding, and then answered questions without signs of coercion.
The transcript and probation documents contain sufficient evidence that Smith knew McClain was a felon and that she had actual notice of the standard probation conditions forbidding contact with convicted felons.
The court found the magistrate adequately considered whether the no-contact condition implicated a fundamental familial-association liberty interest (Wolf Child) and either found Wolf Child inapplicable or, if applicable, performed the required individualized review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements should have been excluded for inadequate Miranda warnings	Smith: warnings were inadequate; statements should be suppressed	Government: warnings were adequate; statements voluntary	Held: warnings were adequately conveyed, understood, and voluntary; any Miranda error harmless; admission upheld
Whether government proved Smith knew McClain was a convicted felon and had notice of the no-contact condition	Smith: government failed to prove knowledge and notice	Government: transcript and probation paperwork show knowledge and actual notice	Held: record contains sufficient evidence of Smith's knowledge and actual notice
Whether the probation condition forbidding contact with McClain unlawfully restricts association	Smith: ban improperly prohibits her from maintaining contact; invokes Wolf Child protections for family association	Government: condition justified for supervision/public safety; Wolf Child doesn’t apply to this non-familial relationship; magistrate did individualized review if required	Held: magistrate did not err; Wolf Child likely inapplicable; even if applicable, court performed required individualized review; no error in prohibiting contact

Burlington Northern, Inc. v. Weyerhaeuser Co., 719 F.2d 304 (9th Cir. 1983) (standard for reviewing factual findings)
United States v. Williams, 435 F.3d 1148 (9th Cir. 2006) (de novo review of Miranda and voluntariness issues)
United States v. Wolf Child, 699 F.3d 1082 (9th Cir. 2012) (special procedural protections where supervised-release condition restricts familial association)
United States v. Laughlin, 933 F.2d 786 (9th Cir. 1991) (standard for review of probation revocation/conditions)
United States v. Pope, 686 F.3d 1078 (9th Cir. 2012) (court may affirm on any basis supported by the record)
Missouri v. Seibert, 542 U.S. 600 (2004) (Miranda doctrinal guidance on warnings and interrogation)
United States v. Bonds, 608 F.3d 495 (9th Cir. 2010) (appellate preservation of arguments and trial-court positions)

Affirmed.