United States v. Lindell Luck
852 F.3d 615
| 6th Cir. | 2017Background
- FBI executed a search warrant at Lindell Luck’s family home after detecting peer-to-peer sharing of child pornography; agents interviewed Luck in private twice during the search and obtained a written, signed confession.
- Agents located two laptops at the residence containing peer-to-peer software and images the government alleged were child pornography; Luck was indicted on three counts for possession and distribution of child pornography under 18 U.S.C. § 2252.
- Luck moved to suppress his statements as Miranda violations and involuntary (due to medication effects); the district court denied suppression after crediting agents’ testimony that interviews were noncoercive and Luck was not in custody.
- Luck sought to force the government to stipulate that the images depicted child pornography; the district court refused and admitted the images at trial; Luck was convicted and sentenced to 78 months’ imprisonment.
- District court excluded extended medical and childhood-treatment testimony under Rule 403 as likely to confuse the issues; court also barred calling Luck’s father solely to invoke the Fifth Amendment. Luck appealed.
Issues
| Issue | Plaintiff's Argument (Gov’t) | Defendant's Argument (Luck) | Held |
|---|---|---|---|
| Admissibility of statements: custody (Miranda) | Interviews were noncustodial: at home, brief, conversational, told he need not speak | Luck was functionally incapacitated by medication and not free to leave | Not in custody; statements admissible |
| Voluntariness (Due Process) | No coercion; agents conversational, warned he could refuse; failure to record not dispositive | Medication impaired him; DOJ recording policy breach warrants adverse inference | Statements voluntary; no coercion; DOJ policy not a constitutional requirement |
| Motion to force stipulation that images were child pornography (Old Chief issue) | Gov’t entitled to present evidence and narrative; Old Chief limited to felon-status stipulations | Luck argued Old Chief requires stipulation like in felon-in-possession cases to avoid prejudicial images | Old Chief limited to felon-status element; court refused to expand it and denied stipulation |
| Evidentiary rulings (medical history & calling father to plead Fifth) | Exclusion of extensive medical history avoided confusion and unfair prejudice; barring father prevented prejudicial inference/collusion | Medical and learning-disability history was probative; father’s testimony crucial and protected by compulsory-process clause | Exclusion and bar were within discretion; any evidentiary error was harmless |
Key Cases Cited
- Old Chief v. United States, 519 U.S. 172 (1997) (limits when a defendant can require a stipulation; holding explicitly confined to felon-status in felon-in-possession cases)
- Miranda v. Arizona, 384 U.S. 436 (1966) (requires warnings before custodial interrogation)
- Oregon v. Mathiason, 429 U.S. 492 (1977) (Miranda custody inquiry focuses on freedom of movement)
- J.D.B. v. North Carolina, 564 U.S. 261 (2011) (a suspect’s age can be relevant to the custody analysis)
- United States v. Binford, 818 F.3d 261 (6th Cir. 2016) (standard of review for Miranda and voluntariness claims)
- United States v. Odeh, 815 F.3d 968 (6th Cir. 2016) (refusing to expand Old Chief beyond felon-status)
- United States v. Boyd, 640 F.3d 657 (6th Cir. 2011) (general rule that defendants cannot selectively stipulate to elements)