United States v. Razak A. Dosunmu, 713 F. App'x 211

Razak Dosunmu was charged with two counts of bribery of a public official under 18 U.S.C. § 201(b)(1) and moved to suppress statements he made to law enforcement as violating Miranda.
The district court denied the suppression motion; Dosunmu was tried and convicted by a jury of two counts of the lesser-included offense—offering illegal gratuities under 18 U.S.C. § 201(c).
The government introduced recorded in-person statements and a nominal payment from Dosunmu to the government official, where Dosunmu described payments as a “gratuity” or “treat” and suggested concealment methods.
At trial the government also relied on Dosunmu’s post-arrest interview statement in closing to argue corrupt intent; the jury acquitted on bribery but convicted on illegal gratuities.
On appeal Dosunmu challenged the denial of his suppression motion, arguing his Miranda waiver was not knowing and intelligent due to agents’ advisements about appointed counsel.
The Fourth Circuit affirmed, holding any Miranda error was harmless beyond a reasonable doubt given the overwhelming, largely undisputed evidence independent of the challenged interview.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dosunmu’s waiver of Miranda rights was knowing and intelligent	Dosunmu: waiver invalid because agents’ advisements undermined understanding of right to appointed counsel	Government: waiver valid and statements admissible	Court assumed potential error but found any Miranda violation harmless beyond a reasonable doubt
Whether admission of the interview statement contributed to conviction	Dosunmu: statement was important and influenced jury; prejudice warrants reversal	Government: other evidence (recorded meeting, payment, admissions) overwhelmingly proved offense	Admission of statement did not contribute to verdict; error (if any) harmless
Whether reliance on the interview in closing increased prejudicial impact	Dosunmu: government emphasis altered weight and trial strategy; defense would have pursued entrapment or joke defense	Government: closing use did not make the statement outcome-determinative given duplicative evidence	Closing reliance insufficient to show prejudice; conviction stands
Whether entrapment or other defenses would have been viable absent the statement	Dosunmu: would have argued entrapment or that he was joking/playing along	Government: recorded conduct and admissions foreclose a viable entrapment defense	Court found entrapment defense unlikely to succeed even excluding the interview; verdict unaffected

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes custodial interrogation warnings requirement)
United States v. Giddins, 858 F.3d 870 (4th Cir. 2017) (harmless-error framework for Miranda violations)
Arizona v. Fulminante, 499 U.S. 279 (1991) (harmless-error analysis and factors to consider)
United States v. Jennings, 160 F.3d 1006 (4th Cir. 1998) (distinguishing bribery from illegal gratuity—mens rea differences)
United States v. Ramos, 462 F.3d 329 (4th Cir. 2006) (discussing entrapment defense)
United States v. Squillacote, 221 F.3d 542 (4th Cir. 2000) (entrainment/entrapment analysis)
Williams v. Zahradnick, 632 F.2d 353 (4th Cir. 1980) (standard for harmless error beyond a reasonable doubt)