United States v. Neiman Adams, 820 F.3d 317

On Aug. 13, 2013 two unmasked men robbed a Virginia, MN credit union at gunpoint; about $53,000 was taken and security video captured the robbery. Adams was arrested three days later.
Adams invoked Miranda on Aug. 16 and declined to answer questions. On Aug. 30 FBI Agent Ball read Miranda warnings; Adams said he understood but refused to sign the form and initially stated he did not want to talk.
During the Aug. 30 custodial interview Adams made some admissions (e.g., claimed to be at a girlfriend’s house, later said he sold his Durango) and continued speaking for ~16 minutes after saying “I don’t want to talk, man.”
At trial the government relied on video, teller identifications, testimony from girlfriends and other witnesses about conduct before/after the robbery, and recorded phone calls; Detective Hedstrom testified briefly about Adams’s interrogation statements.
District court denied Adams’s motion to suppress, concluding his silence phrase was ambiguous and he implicitly waived Miranda; Adams was convicted and sentenced to 240 months (plus an 18‑month consecutive revocation sentence).

Issue	Adams’ Argument	Government’s Argument	Held
Whether Adams unequivocally invoked right to remain silent during Aug. 30 interview	Adams: “I don’t want to talk, man” was an unambiguous invocation requiring cessation of questioning	Government: Phrase was ambiguous (e.g., “I mean”) and Adams continued to engage, so no clear invocation	Court: No clear error—statement ambiguous; not an unequivocal invocation
Whether Adams waived Miranda rights	Adams: Refusal to sign form, prior invocation, and dislike of cops show no intent to waive	Government: He was warned, understood, and then voluntarily spoke—waiver can be implied from words/actions	Court: Waiver was implied and voluntary; district court did not err
Whether any Miranda error was harmless	Adams: Statements were prejudicial and contradicted his defense	Government: Independent, overwhelming identification and other evidence minimized any impact	Court: Any error would be harmless given independent strong evidence of guilt
Whether the 240‑month sentence (and consecutive 18‑month revocation sentence) was substantively unreasonable	Adams: Court failed to weigh mitigating factors sufficiently; sentence greater than necessary	Government: District court considered the factors and acted within discretion	Court: Sentence was not substantively unreasonable; no abuse of discretion

Miranda v. Arizona, 384 U.S. 436 (1966) (warnings and right to silence/ counsel required for custodial interrogation)
North Carolina v. Butler, 441 U.S. 369 (1979) (waiver of Miranda rights may be implied from words and conduct)
Berghuis v. Thompkins, 560 U.S. 370 (2010) (Miranda warning + understanding + uncoerced statement can establish implied waiver)
United States v. Havlik, 710 F.3d 818 (8th Cir. 2013) (equivocal language defeats a clear invocation of rights)
Gall v. United States, 552 U.S. 38 (2007) (appellate review standard for substantive reasonableness of sentences)