United States v. Justin Treanton, 57 F.4th 638

In Jan 2020 an undercover officer in New Zealand received child‑pornography files from a user who identified himself as a 35‑year‑old U.S. man and said the images depicted his four‑year‑old daughter; agents traced the IP to Bettendorf, Iowa and identified Justin Treanton as the lone matching male resident.
Agents executed a warrant at Treanton’s residence, then located and entered a different house’s garage (with owner’s consent) where they found Treanton hiding behind debris.
During the garage encounter an agent struck Treanton, briefly handcuffed him, then removed the cuffs and told him he was not under arrest.
Agents interviewed Treanton in a vehicle for over 90 minutes, repeatedly told him he was free to leave, obtained incriminating statements and consent to search two cell phones; near the end a county attorney directed his arrest and agents gave Miranda warnings.
Treanton moved to suppress pre‑Miranda statements; the district court denied suppression. He pleaded guilty (reserving the suppression issue) and was sentenced to 600 months (within the advisory guideline range).
On appeal the Eighth Circuit affirmed denial of suppression (finding no custodial interrogation) and affirmed the sentence as reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pre‑Miranda statements must be suppressed because interrogation was custodial	Treanton: garage force and handcuffs made later vehicle questioning custodial, so Miranda required	Government: restraints were temporary, agents released him, told him he was not under arrest and free to leave; no coercion in vehicle	Not custodial; statements admissible
Whether 600‑month sentence was unreasonable	Treanton: court undervalued acceptance of responsibility, family and mental‑health mitigation	Government: within guideline range; offense especially aggravating (production involving daughter, extensive collection, obstruction)	Sentence reasonable; no abuse of discretion

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required before custodial interrogation)
California v. Beheler, 463 U.S. 1121 (1983) (custody requires formal arrest or equivalent restraint)
Berkemer v. McCarty, 468 U.S. 420 (1984) (custody assessed by whether reasonable person would feel free to terminate questioning)
United States v. Griffin, 922 F.2d 1343 (8th Cir. 1990) (sets representative six‑factor indicia of custody)
United States v. Rodriguez, 711 F.3d 928 (8th Cir. 2013) (temporary force/restraint may be investigative, not arrest)
United States v. Laws, 819 F.3d 388 (8th Cir. 2016) (advice that suspect is free to leave generally negates custodial trappings)
United States v. Flores‑Sandoval, 474 F.3d 1142 (8th Cir. 2007) (post‑interview arrest does not by itself make prior questioning custodial)
United States v. Sanchez‑Velasco, 956 F.3d 576 (8th Cir. 2020) (interview ending in arrest may indicate custody but is not dispositive)
United States v. Axsom, 289 F.3d 496 (8th Cir. 2002) (de novo review of custody legal determination on appeal)