United States v. Jose Ramirez-Estrada, 749 F.3d 1129

Ramirez-Estrada, a previously deported non‑citizen, was charged with attempted illegal reentry (8 U.S.C. §1326) and false claim of U.S. citizenship (18 U.S.C. §911) and convicted after a jury trial.
At trial Ramirez-Estrada testified that he approached the Port of Entry seeking medical treatment for an untreated jaw injury; CBP Officer Ponce de Leon testified the defendant claimed U.S. citizenship and did not complain of health problems.
After arrest and after Ramirez-Estrada invoked his Miranda right to counsel, CBP Officer Nicasio asked routine booking questions about health and identifying marks; Ramirez-Estrada answered "no" to health problems and noted scars/broken nose but did not mention his jaw injury.
The government used Officer Nicasio’s testimony in rebuttal to undermine Ramirez-Estrada’s credibility, arguing his failure to mention the jaw injury contradicted his trial story.
Ramirez-Estrada objected under Doyle v. Ohio; the district court admitted the rebuttal testimony. The Ninth Circuit reviewed de novo and reversed, finding a Doyle violation that was not harmless beyond a reasonable doubt.

Issue	Government's Argument	Ramirez‑Estrada's Argument	Held
Whether introducing post‑Miranda booking answers to impeach a defendant by highlighting omitted facts (post‑invocation silence) violates Doyle v. Ohio	Answers were directly inconsistent with trial testimony; no Doyle problem because routine booking questions are permissible and there was no Miranda violation	He invoked Miranda; his booking answers were not directly inconsistent — only omissions (failure to mention jaw injury) were used to impeach, which draws impermissible meaning from post‑invocation silence	Admission of Officer Nicasio’s testimony violated Doyle because it invited inference from post‑invocation silence; error not harmless; conviction reversed and remanded

Doyle v. Ohio, 426 U.S. 610 (constitutional bar on using post‑Miranda silence to impeach)
Miranda v. Arizona, 384 U.S. 436 (Miranda warnings and right to remain silent)
Anderson v. Charles, 447 U.S. 404 (post‑arrest, post‑waiver inconsistent statements may be used to impeach where no meaning drawn from silence)
Caruto v. United States, 532 F.3d 822 (9th Cir. 2008) (distinguishes omissions after invocation from true prior inconsistent statements; Doyle violation even where Miranda complied)
Pennsylvania v. Muniz, 496 U.S. 582 (routine booking questions are generally admissible despite Miranda)
Jenkins v. Anderson, 447 U.S. 231 (failure to state a fact previously may be used for impeachment in some circumstances)