United States v. Medina, 19 F. Supp. 3d 518

Medina is charged with conspiracy to distribute crack cocaine and marijuana, and with firearm offenses under 18 U.S.C. § 924(c) and § 924(j).
NYPD investigated July 28, 2012 shootings in the Bronx, including a non-fatal shooting near Scotty’s and a fatal shooting of Gary Clark; Medina is linked to these events.
Medina was asleep in his girlfriend’s apartment when police entered; he was questioned without Miranda warnings during an early encounter in the stairwell and hallway.
Medina was later arrested outside the apartment and transported to the precinct; he was questioned over lengthy periods, with Miranda warnings administered only later in the evening.
The defense sought suppression of all statements as fruits of an unlawful arrest and Miranda violations; the court held suppression is not warranted.
A post-arrest identification and further questioning followed after the arrest, including a subsequent interview at the 47th Precinct with Miranda warnings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was probable cause to arrest Medina	Medina: arrest lacked probable cause based on informant tip.	Medina: insufficient reliability of informant undermines probable cause.	Probable cause supported; arrest is valid.
Whether the Payton entry violated the Fourth Amendment	Arrest inside home without warrant violated Payton.	No Payton violation; entry was lawful or not a true entry.	No Payton violation; post-arrest statements admissible under Harris.
Whether statements in the stairwell were Miranda-protected custodial interrogation	Stairwell questioning required Miranda warnings.	Not custody; no warnings needed.	No custodial interrogation; stairwell statements admissible.
Whether the 47th Precinct questioning violated Miranda or Seibert two-stage rule	Two-step interrogation or failure to warn violated Miranda and Seibert.	Any two-step process was not deliberate; warnings given; Seibert not triggered.	Post-arrest statements admissible; no Seibert violation; warnings given prior to questioning.
Whether Medina did or did not knowingly and voluntarily waive Miranda rights, including requests for counsel	Detentions and ambiguous Form 5 response undermine waiver validity.	Waiver voluntary; signs and verbal affirmations show understanding; requests for counsel were not clearly invoked.	Waiver voluntary; no suppression for lack of counsel invocation.

United States v. Gates, 462 U.S. 213 (U.S. 1983) (reliability and basis of informant for probable cause; totality of circumstances)
United States v. Wagner, 989 F.2d 69 (2d Cir. 1993) (informant reliability corroboration by independent evidence)
Valentine v. United States, 539 F.3d 88 (2d Cir. 2008) (probable cause based on totality of circumstances and informant tips)
Missouri v. Seibert, 542 U.S. 600 (U.S. 2004) (two-step interrogation regime; deliberate strategy to obtain postwarning statements)
Oregon v. Elstad, 470 U.S. 298 (U.S. 1985) (Elstad doctrine; admissibility of subsequent postwarning statements)
United States v. Jaswal, 47 F.3d 539 (2d Cir. 1995) (valid waiver requires knowing and voluntary understanding)
Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel; once invoked, police may not reinitiate interrogation)
Payton v. New York, 445 U.S. 573 (U.S. 1980) (home entry for arrest requires warrant absent exigent circumstances)
North Carolina v. Butler, 441 U.S. 369 (U.S. 1979) (waiver of rights; non-written waiver sufficient if knowingly and voluntarily given)
Howes v. Fields, 132 S. Ct. 1181 (S. Ct. 2012) (custody factors and interrogation risk in Miranda analysis)