United States v. Hogan, 1:16-cr-00215

Two searches: Sept. 23, 2015 (327 E. Philadelphia St., Apt. 1) and Feb. 26, 2016 (766 W. Market St., Apt. 4). Each search produced heroin, drug paraphernalia, a firearm, and ~$2,400 cash. Defendant Christian Hogan was present, handcuffed, and questioned at each search.
Hogan indicted on federal drug and firearm charges; he moved to suppress physical evidence and oral statements from both searches.
Judge Caldwell previously rejected Hogan’s challenges to the search-warrant affidavits and denied suppression of physical evidence, but found credibility disputes over whether Miranda warnings were given and ordered an evidentiary hearing on that issue.
At the suppression hearing the government called four officers who testified that Hogan was read Miranda warnings at each site, that Hogan said he understood, and then made incriminating statements; no audio recordings or signed waivers were produced.
Hogan did not testify or present contrary evidence. He argued suppression was required because officers never obtained an explicit waiver of Miranda rights.
The court found the officers’ testimony credible, concluded Miranda warnings were given, and held Hogan’s voluntary, uncoerced statements constituted an implied waiver.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements made during arrests at the two searched apartments must be suppressed for Miranda violations	Hogan: He was not given Miranda warnings and did not waive rights; statements therefore inadmissible	Government: Officers read Miranda warnings, Hogan acknowledged understanding, then voluntarily spoke — waiver may be implied	Denied. Court credited officers, found warnings were given and Hogan’s uncoerced statements amounted to a knowing, voluntary waiver
Whether an explicit waiver is required for admissibility	Hogan: No explicit oral or written waiver was obtained, so statements should be suppressed	Government: Waiver need not be explicit; conduct and statements can establish waiver	Denied. Court applied precedent allowing inferred waivers from subsequent uncoerced statements

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires warnings about right to remain silent and right to counsel)
Maryland v. Shatzer, 559 U.S. 98 (2010) (waiver must be knowing, intelligent, and voluntary)
North Carolina v. Butler, 441 U.S. 369 (1979) (waiver need not be express; can be implied by conduct)
Berguis v. Thompkins, 560 U.S. 370 (2010) (silence after Miranda warning plus subsequent statements can constitute an implied waiver)