United States v. Jacques, 2014 U.S. App. LEXIS 4486

On Nov. 5, 2008 the Macedonia Church (predominantly African-American) in Springfield, MA, was burned in an arson investigation led by ATF/FBI/MSP/Springfield PD.
Tip and controlled buys led investigators to Benjamin Haskell and Michael Jacques; Haskell confessed and agreed to cooperate; he arranged a meeting with Jacques and an undercover trooper.
At a Jan. 15, 2009 meeting, Jacques made incriminating statements on tape, was detained, transported to MSP offices, and knowingly waived Miranda before a videotaped interrogation that lasted ~6.5 hours.
Interrogators used Reid-style techniques: exaggerating evidence, minimizing offense, suggesting cooperation could yield leniency and noncooperation harsher treatment, and referencing Jacques's elderly father.
Jacques signed a waiver of prompt presentment roughly 6 hours and 4 minutes after being taken into custody; about 25 minutes after signing, following a cigarette break, he confessed.
Jacques moved to suppress, arguing (1) his confession was involuntary due to coercive tactics and (2) his right to prompt presentment (and §3501(c) six-hour safe harbor) was violated; the district court denied suppression and a jury convicted him on all counts. The First Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of confession (Fifth Amendment)	Jacques: Reid techniques, threats of harsher punishment, appeals to family ties, and deception overbore his will and rendered confession involuntary	Government: Defendant was experienced with criminal system, remained calm, breaks were permitted, and confession resulted from judgeable choices not coercion	Court: Totality of circumstances shows confession voluntary; tactics fell within permissible deception; threats and family appeals did not demonstrably overbear Jacques's will
Right to prompt presentment / §3501(c) six-hour rule	Jacques: Waiver occurred after the six-hour safe-harbor; delay unreasonable and not justified by transportation; waiver therefore untimely and statements inadmissible under McNabb–Mallory	Government: Delay de minimis (~4 minutes past six hours), magistrate unavailable, waiver was knowing and voluntary, and delay was not a purposeful circumvention of presentment	Court: Four-minute excess was a minor miscalculation; waiver knowingly and voluntarily executed; delay not unreasonable/unnecessary under McNabb–Mallory; statements admissible

Dickerson v. United States, 530 U.S. 428 (Miranda rights and voluntariness standard)
Corley v. United States, 556 U.S. 303 (McNabb–Mallory rule and §3501 framework)
McNabb v. United States, 318 U.S. 332 (prompt presentment principle)
Mallory v. United States, 354 U.S. 449 (limits on delay for interrogation and presentment)
Lynumn v. Illinois, 372 U.S. 528 (psychological coercion tied to family/benefits can render confession involuntary)
Frazier v. Cupp, 394 U.S. 731 (police misrepresentations do not automatically render confessions involuntary)
United States v. Jackson, 918 F.2d 236 (1st Cir.) (threats/promises considered under totality; susceptibility matters)
United States v. Hughes, 640 F.3d 428 (1st Cir.) (totality-of-circumstances voluntariness review)
United States v. Mejía, 600 F.3d 12 (1st Cir.) (standard of review for suppression rulings)