United States v. Jerry Wells, Jr., 690 F. App'x 338

In Feb 2014 Elyria police executed a warrant at a Case Avenue house after controlled buys of heroin; they found heroin, MDMA, marijuana plants, and a handgun.
While the search was ongoing officers stopped Jerry L. Wells driving nearby, transported him to the house, and arrested him on drug charges; exact basis and timing of the stop are not in the record.
Wells received Miranda warnings at the house and again at the station and made inculpatory statements admitting residence, ownership of the gun, and drug sales; a cell phone was seized at some point but timing is unclear.
Wells moved to suppress physical evidence and later sought suppression of post-arrest statements and the cell phone as fruits of an allegedly unlawful traffic stop; the district court assumed the stop was illegal but denied suppression of the statements and reserved ruling on the phone.
Wells pleaded guilty while preserving the right to appeal suppression rulings; he appealed only the denial as to his statements (and attempted to raise the phone issue, but the district court had not ruled and Wells abandoned it below).
The Sixth Circuit affirmed: it upheld denial of suppression for the post-arrest statements based on attenuation analysis and declined to address the cell phone because Wells failed to preserve that issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of the initial stop	Stop was unlawful (not in area, no probable cause), so all fruits should be suppressed	Government offered multiple, inconsistent justifications (Terry stop for missing-juvenile probe; driving-under-suspension) but produced no supporting evidence	Court assumed stop unlawful because government failed to prove it
Admissibility of post-arrest statements	Statements were fruits of the illegal stop and should be suppressed under Brown multi-factor attenuation test	Statements are admissible because intervening lawful events (valid search warrant, contraband found, probable cause to arrest) attenuated the taint; Harris supports admissibility of later stationhouse confession	Statements at the house: close call but admissible (balance tipped slightly to government). Stationhouse statement: clearly attenuated and admissible.
Admissibility of seized cell phone	Phone seized during initial stop and is fruit of unlawful stop, so suppress	Government ambiguous about timing; district court required evidentiary hearing	No ruling by district court and issue not preserved on appeal; appellate court declined to decide

Brown v. Illinois, 422 U.S. 590 (1975) (announces multi-factor attenuation test for confessions after unlawful arrest)
New York v. Harris, 495 U.S. 14 (1990) (holding that statements obtained at stationhouse can be admissible despite earlier unlawful entry when probable cause existed to arrest)
Miranda v. Arizona, 384 U.S. 436 (1966) (requires warnings to protect Fifth Amendment privilege against self-incrimination)
Wong Sun v. United States, 371 U.S. 471 (1963) (discusses "fruit of the poisonous tree" and attenuation concept)
Devenpeck v. Alford, 543 U.S. 146 (2004) (probable cause assessment based on facts known to arresting officer)
Payton v. New York, 445 U.S. 573 (1980) (limits warrantless home arrests)
Rawlings v. Kentucky, 448 U.S. 98 (1980) (spontaneous reaction to discovery of contraband can be an intervening circumstance)
United States v. Gross, 662 F.3d 393 (6th Cir. 2011) (Sixth Circuit discussion of exclusionary rule deterrence and attenuation analysis)