United States v. Taylor, 745 F.3d 15

Background

Taylor, Rosario, and Vasquez were convicted in SDNY for Hobbs Act robbery conspiracy and related offenses tied to a Midtown Manhattan pharmacy robbery.
Luana Miller cooperated after arrest and led police to the three defendants; Miller’s cooperation was a central trial issue.
Taylor was arrested early on April 9, 2009 and allegedly ingested Xanax pre-arrest, with conflicting evidence on actual ingestion and effects.
April 9: Taylor waived Miranda rights, gave a long statement; investigators testified Taylor nodded off and was intermittently lucid.
April 10: Taylor separately confessed again after being re-advised; evidence suggested he remained incoherent at times and heavily sleep-deprived.
The district court admitted Taylor’s April 9 and 10 statements; Taylor’s April 9 confession was deemed involuntary and tainted the April 10 confession, leading to suppression and vacating convictions on appeal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Taylor's April 9 Miranda waiver and statement voluntary?	Taylor argues his impairment rendered his waiver involuntary.	Government contends waiver was knowing and voluntary despite sleepiness.	April 9 statement not voluntary; waiver tainted by impairment.
Was Taylor's April 10 confession tainted by the first coerced confession?	Second waiver may be influenced by the first coerced confession.	Second confession could be voluntary independent of first.	Second waiver/statement involuntary due to taint from first confession and ongoing incapacity.
Was the erroneous admission of the involuntary confession harmless?	Admission did not prejudicially affect the outcome.	Errors were harmless beyond a reasonable doubt due to other evidence.	Admission was not harmless; convictions vacated and remanded.
Did the redacted co-defendant statement violate the Confrontation Clause (Bruton concerns)?	Redacted confession implicates co-defendants and cannot be admitted without violating Bruton.	Limiting instructions and redaction can cure Bruton problems.	Redactions were impermissibly revealing; Bruton error found; remand for new trial.

Key Cases Cited

Berghuis v. Thompkins, 560 U.S. 370 (U.S. 2010) (Miranda waiver knowledge and voluntariness standard)
Dickerson v. United States, 530 U.S. 428 (U.S. 2000) (Miranda warnings necessity alongside voluntariness)
Oregon v. Elstad, 470 U.S. 298 (U.S. 1985) (Temper of initial vs. subsequent statements in totality of circumstances)
United States v. Plugh, 648 F.3d 118 (2d Cir. 2011) (knowing and voluntary waiver standard)
Colorado v. Connelly, 479 U.S. 157 (U.S. 1986) (mental state and coercion in voluntariness analysis)
Minсey v. Arizona, 437 U.S. 385 (U.S. 1978) (police overreaching and interrogation of a seriously injured suspect)
Salameh v. United States, 152 F.3d 88 (2d Cir. 1998) (voluntariness despite weakened mental state)
Tankleff v. Senkowski, 135 F.3d 235 (2d Cir. 1998) (taint from prior coerced confession and second confession)
United States v. Bayer, 331 U.S. 532 (1947) (presumption of compulsion when prior confession exists)
Jass v. United States, 569 F.3d 47 (2d Cir. 2009) (redaction adequacy under Bruton and confidentiality concerns)
Gray v. Maryland, 523 U.S. 185 (U.S. 1998) (redacted statements implicating non-declarants and Bruton risk)
Bruton v. United States, 391 U.S. 123 (U.S. 1968) (confrontation risk from co-defendant's out-of-court statements)
Tutino, 883 F.2d 1125 (2d Cir. 1989) (acceptable redactions and substitutions for co-defendant references)
Williams, 936 F.2d 698 (2d Cir. 1991) (acceptable neutral substitutions in redaction)
Kyles, 40 F.3d 519 (2d Cir. 1994) (redaction analysis and the risk of implying culpability)