United States v. Sturdivant, 796 F.3d 690

Sturdivant pleaded guilty to four counts of armed robbery and one count of using a firearm during and in relation to a crime of violence; he moved to suppress post-arrest statements reserved in his plea.
Prosecution linked Sturdivant to four robberies via fingerprint from a bag left at the fourth scene and DNA evidence later claimed by officers (which they knew did not exist).
Sturdivant was arrested April 27, 2012, interviewed first in an unrecorded session and then in a recorded session on April 28, 2012 after a break during questioning.
During the April 28 interview, officers provided Miranda warnings, obtained a waiver, and Sturdivant confessed to all four robberies on video; he later directed officers to the discarded firearm.
An evidentiary suppression hearing was held April 23, 2014; the district court denied the suppression motion, finding Sturdivant appeared capable and not suffering from diabetes during interviews.
On appeal, the Seventh Circuit affirms, holding the confessions voluntary and not coerced by diabetes, false DNA claims, Miranda practices, or purported promises.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the post-arrest confessions were voluntary.	Sturdivant (Sturdivant) contends coercive tactics and diabetic condition rendered confessions involuntary.	The government argues confessions were voluntary under totality of circumstances.	Affirmed; confessions voluntary.
Whether the officers’ handling of diabetes evidence renders the confessions involuntary.	Diabetes symptoms and vomiting indicate coerced confession.	No evidence of diabetes-induced coercion; witnesses showed faculties intact.	Affirmed; diabetes did not coercively affect voluntariness.
Whether false DNA evidence about the crime scene coerced confessions.	False DNA claim manipulated the defendant into confessing.	Lies about evidence do not render confession involuntary if rational choice remains possible.	Affirmed; no coercion from false DNA evidence.
Whether Miranda warnings timing and lack of written waiver tainted voluntariness.	Oral warnings and unrecorded waivers should render statements involuntary.	Written waiver post-confession is not required to render statements involuntary; oral waivers valid.	Affirmed; lack of written waiver did not render statements involuntary.
Whether promised access to his mother coerced confession.	Promised visit to mother after cooperation coerced confession.	Promised benefit did not override free will; at most a non-overriding incentive.	Affirmed; promise did not render confessions involuntary.

Colorado v. Connelly, 479 U.S. 157 (U.S. 1986) (coercion necessary for involuntariness; rational decision possible without coercion)
Lego v. Twomey, 404 U.S. 477 (U.S. 1972) (government bears burden of proving voluntariness by preponderance of the evidence)
United States v. Montgomery, 555 F.3d 623 (7th Cir. 2009) (de novo review of voluntariness; credibility determinations defer to district court)
United States v. Huerta, 239 F.3d 865 (7th Cir. 2001) (coercion factors include age, education, mental state, detention length, interrogation nature)
United States v. Murdock, 491 F.3d 694 (7th Cir. 2007) (written waiver not required for voluntariness of oral waiver/confession)
United States v. Ceballos, 302 F.3d 679 (7th Cir. 2002) (lie about suspect’s connection to crime not always involuntary coercion)
United States v. Conner v. McBride, 375 F.3d 643 (7th Cir. 2004) (police may mislead to obtain confession if rational choice remains possible)
United States v. Gilliam, 372 F.3d 848 (7th Cir. 2004) (coercion analysis under totality of circumstances includes deception/pressure factors)
United States v. Villalpando, 588 F.3d 1124 (7th Cir. 2009) (factor-based coercion analysis with age/education/experience considerations)