United States v. Jennings, 5:24-cr-00334

Ashley Shanta Jennings was charged with making a false statement to federal law enforcement in violation of 18 U.S.C. § 1001(a)(2).
The disputed statements were made to federal agents on March 31, 2023, during interviews at or near her home regarding a fugitive's location.
Jennings moved to suppress the statements, arguing she was effectively in custody without a Miranda warning and that the statements were not recorded.
The Government opposed both suppression and an evidentiary hearing, arguing Jennings was not in custody, her statements were voluntary, and she failed to present specific factual disputes.
The Court reviewed facts, primarily from the Government’s response, finding Jennings was not under arrest, not handcuffed, was interviewed in familiar surroundings, and voluntarily engaged with officers.

Issue	Jennings' Argument	Government's Argument	Held
Was Jennings in custody requiring Miranda?	She was subject to custodial interrogation, so Miranda warnings were required.	She was not in custody; no Miranda required.	No custodial interrogation; no Miranda.
Was an evidentiary hearing warranted?	Hearing needed due to lack of specifics about interview circumstances and voluntariness of statements.	Allegations too vague; Jennings knows the facts; hearing would be a fishing expedition.	Denied; no factual dispute presented.
Were statements involuntary or coerced?	Statements were not voluntary; more facts needed to decide voluntariness.	No evidence of coercion or involuntariness; interviews brief and non-threatening.	Statements voluntary.
Should statements be suppressed?	Yes, due to constitutional violations in obtaining them.	No, as neither Miranda nor voluntariness violations exist.	Motion to suppress denied.

Jackson v. Denno, 378 U.S. 368 (1964) (entitlement to hearing for disputed confessions)
Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation)
United States v. Lamy, 521 F.3d 1257 (10th Cir. 2008) (home interviews by law enforcement generally not custodial)
United States v. Jones, 523 F.3d 1235 (10th Cir. 2008) (no custody in police vehicle, short non-coercive questioning)
United States v. Revels, 510 F.3d 1269 (10th Cir. 2007) (defining custody for Miranda purposes)