United States v. Soudry
5:24-cr-00402
W.D. Okla.May 16, 2025Background
- Alias Bah De Za Lawrence Soudry was charged with involuntary manslaughter arising from a fatal vehicle collision in Oklahoma, allegedly while under the influence of alcohol and marijuana.
- After the accident, Soudry was taken to a hospital; Trooper Lisa Jorgensen (Drug Recognition Expert) questioned him, obtained his consent for a blood draw, and conducted impairment tests.
- Soudry made statements to Trooper Jorgensen before and after being read his Miranda rights, and he also made statements to his uncle while under arrest.
- Soudry filed a motion to suppress his statements and the results of the blood test, arguing his rights under the Fourth and Fifth Amendments were violated.
- The court held a hearing, received witness testimony and evidence, and reviewed relevant case law to determine the admissibility of this evidence.
Issues
| Issue | Soudry's Argument | Government's Argument | Held |
|---|---|---|---|
| Statements before Miranda warnings | Statements were result of custodial interrogation, should be suppressed | Not in custody; Miranda not required | Not in custody; Miranda not required—statements admissible |
| Statements after Miranda warnings | Subsequent Miranda did not cure taint from earlier violation | No Miranda violation occurred with initial statements | No taint; statements admissible |
| Statements to uncle | Should be suppressed; Trooper overheard statements | No governmental coercion involved; not subject to Miranda | No Miranda issue; statements admissible |
| Blood test consent | Consent not voluntary due to age, impairment, and circumstances | Consent was unequivocal, specific, and voluntary | Consent was voluntary; blood test results admissible |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes requirement for Miranda warnings during custodial interrogation)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (clarifies Miranda custody standard as an objective inquiry)
- Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (sets standard for voluntariness of consent under the Fourth Amendment)
- Missouri v. McNeely, 569 U.S. 141 (U.S. 2013) (warrantless blood draws require an exception such as consent)
- Colorado v. Connelly, 479 U.S. 157 (U.S. 1986) (focus for Miranda is governmental coercion, not individual vulnerability)