United States v. Joshua Riley, 920 F.3d 200

Riley, released from federal prison in 2016, served five years supervised release after a 2013 drug conviction; he tested positive for meth multiple times but was not previously revoked.
On March 16, 2018, local officers found methamphetamine in Riley’s car; he was arrested on a state possession charge and his federal probation officer sought arrest for supervised-release violations.
While held in the county jail and not given Miranda warnings, Riley told his probation officer he used meth daily for months and had distributed about an ounce weekly; he signed a written statement repeating those admissions.
At the revocation hearing the district court relied on Riley’s statements to find he committed a Grade A violation (distribution) and sentenced him to 20 months’ imprisonment (below the Guidelines range).
Riley appealed, arguing (1) his Fifth Amendment right was violated because custodial, unwarned statements should be excluded; and (2) the court erred in relying on uncorroborated admissions to find distribution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admitting Riley’s unwarned, custodial statements to his probation officer violated the Fifth Amendment	Miranda warnings were required because Riley was in custody, so his unwarned statements should be suppressed	Revocation proceedings are not criminal prosecutions; Fifth Amendment protection (and suppression remedy) applies only when compelled statements are used in a criminal trial	Court held no Fifth Amendment violation because revocation proceedings are not part of a criminal prosecution, so use of the statements did not violate the Self-Incrimination Clause
Whether the government needed independent corroboration of Riley’s out-of-court confession to prove distribution in revocation proceedings	Riley argued conviction-equivalent corroboration rule applies; uncorroborated confession insufficient to prove Grade A distribution	Because revocation is not a criminal trial, the corroboration rule for criminal convictions does not apply; admissions are admissible evidence in revocation hearings	Court held corroboration was not required; Riley’s admissions were sufficient by a preponderance to support the revocation finding

Miranda v. Arizona, 384 U.S. 436 (examines custodial interrogation and requirement of warnings)
Minnesota v. Murphy, 465 U.S. 420 (probationer’s statements to officer and limits of Fifth Amendment in revocation contexts)
Chavez v. Martinez, 538 U.S. 760 (Fifth Amendment violation occurs only when compelled statements are used in a criminal case)
Morrissey v. Brewer, 408 U.S. 471 (parole revocation is not a criminal prosecution; due process standards for revocation)
United States v. Armstrong, 187 F.3d 392 (4th Cir.) (exclusionary rule not applied in supervised-release revocation proceedings for Fourth Amendment violations)
United States v. Stephens, 482 F.3d 669 (rule that criminal convictions cannot rest solely on uncorroborated extrajudicial confessions)
United States v. Padgett, 788 F.3d 370 (standard of proof in supervised-release revocation is preponderance of the evidence)