United States v. Medunjanin
752 F.3d 576
2d Cir.2014Background
- Medunjanin travelled to Pakistan with Zazi and Ahmedzay to join al-Qaeda but was diverted to training and return to plan NYC subway bombings.
- He was arrested in January 2010 after driving a high-speed collision on the Whitestone Expressway to trigger an explosion.
- A district court held a suppression hearing and denied Medunjanin’s motion to suppress postarrest statements.
- Earlier, September 2009, JTTF officers spoke with Medunjanin at his apartment and then at the U.S. Attorney’s Office; interview was described as voluntary.
- After arrest, he underwent multiple Miranda warnings and signed waivers; the government sought to question him without Gottlieb present based on representation.
- A superseding indictment charged nine counts related to terrorism; Medunjanin was convicted on all counts and sentenced to life plus 95 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pre-custody invocation of counsel was required under Miranda/Edwards | Medunjanin claimed pre-custody invocation occurred | Government contends no clear invocation pre-custody | No clear invocation pre-custody; questioning after arrest permissible |
| Whether waivers of Miranda rights were knowing and voluntary | Waivers were involuntary due to coercion/attorney-cost pressures | Waivers were knowingly and voluntarily given | Waivers were knowingly and voluntarily made under totality of circumstances |
| Whether pre-indictment government conduct violated the Sixth Amendment | Interference with counsel before indictment violated Sixth Amendment | Right to counsel attaches only after proceedings begin | No Sixth Amendment violation; right to counsel not triggered pre-indictment |
| Whether the government’s handling of counsel access violated substantive due process | Interference with attorney contact violated due process | No due process violation; rights limited to specific Amendments | No substantive due process violation; claims meritless |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (established Miranda warnings and right to counsel during custodial interrogation)
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (once counsel is requested, interrogation must cease until counsel present)
- McNeil v. Wisconsin, 501 U.S. 171 (U.S. 1991) (Miranda rights may be waived knowingly and voluntarily)
- Davis v. United States, 512 U.S. 452 (U.S. 1994) (prevents compulsion, governs whether rights are invoked and waived)
- Gouveia v. New Jersey, 467 U.S. 180 (U.S. 1984) (established when Sixth Amendment right to counsel attaches)
- Montejo v. Louisiana, 556 U.S. 778 (U.S. 2009) (clarified scope of Miranda waiver in custodial settings)
- Burbine v. United States, 475 U.S. 412 (U.S. 1986) (attorney’s statements cannot invoke the suspect’s rights; invocation must be by the suspect)
- Salinas v. Texas, 133 S. Ct. 2174 (S. Ct. 2013) (track of invocation of privilege; privilege not self-executing)