United States v. STILE, 1:11-cr-00185

Defendant James Stile was arrested after a masked gunman robbed a Maine pharmacy; deputies stopped him about 25 minutes later on Route 16 based on reasonable suspicion.
Pursuant to searches executed at his Sangerville home, officers found a marijuana grow operation; a separate marijuana-related warrant followed.
Interviews occurred Sept. 13 (home/scene), Sept. 15 (dog welfare discussion), Sept. 16 (interview with warnings, some unwarned questioning), Sept. 19 (with warnings) and Sept. 22 (transfer to federal authorities).
Stile challenged the statements as Miranda/ Sixth Amendment violations and as involuntary; the magistrate judge issued proposed findings recommending partial suppression.
The court found a Miranda violation pre-warning on Sept. 16, but otherwise admitted most statements after proper warnings; the Sixth Amendment right to counsel was not violated, and the statements were voluntary overall.
The court recommended granting in part the Miranda-based motion (suppressing unwarned statements from Sept. 16) and denying the involuntary-motion in all other respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a valid Miranda waiver occurred at each interrogation	Stile asserts rights were invoked; warnings were not properly scrupulously honored	Stile never knowingly waived when questioned without fresh warnings	Partially granted; unwarned Sept. 16 statements suppressed, others admitted
whether Edwards/Mosley protections were violated when questioning resumed after invocation	Rights to counsel and silence were not properly respected upon resumption	Any resumption was after fresh warnings or initiated by Stile	No overall Edwards violation; Mosley standards satisfied for most sessions under fresh warnings
Whether statements were involuntary under the totality of circumstances	Coercive withdrawal symptoms and dog-welfare pressures overbore will	No coercive conduct; Stile remained capable of rational decisionmaking	Statements voluntary; only Sept. 16 unwarned window suppressed
Whether the Sixth Amendment right to counsel was violated	Counsel should have been present during interrogation	Stile never asserted a right to counsel during many sessions; waiver valid	No Sixth Amendment violation; waiver valid except for the unwarned Sept. 16 window
Scope of admissibility of statements following fresh warnings	Subsequent statements after warnings should be suppressed if prompted by interrogation	Once warned, Stile knowingly waived and continued voluntarily	Admissible after proper Miranda warnings; suppress unwarned segment from Sept. 16

United States v. Barone, 968 F.2d 1378 (1st Cir. 1992) (Mosley-like scrupulous honoring factors for right to silence)
United States v. Andrade, 135 F.3d 104 (1st Cir. 1998) (Admissibility after second round with warnings in same offense)
United States v. Lugo Guerrero, 524 F.3d 5 (1st Cir. 2008) (Admissibility after separate, warned interview for same crime)
United States v. Thongsophaporn, 503 F.3d 51 (1st Cir. 2007) (Initiation by defendant; warnings and voluntariness considerations)
United States v. Ortiz, 177 F.3d 108 (1st Cir. 1999) (Edwards/Initiation and counsel-related considerations)