United States v. Tineo-Gonzalez, 893 F.3d 64

Tineo traveled from the Dominican Republic to Puerto Rico in a boat carrying over 210 kg of cocaine and 2 kg of heroin; he was captured hours after unloading.
Arresting officers allegedly gave Miranda warnings; Tineo was interviewed by Puerto Rico police and later by DEA agents, who obtained a written Miranda waiver and inculpatory statements.
After indictment, the district court set a pretrial-motion deadline (motions due 14 days before trial); trial was later set for March 28, 2016.
The government filed its evidence designation (including DEA statements) in February and amended it on March 23 to add police statements.
Tineo moved to suppress the police statements on March 25 (three days before trial), claiming Miranda violations and coercion; the district court denied the motion as untimely under the scheduling order.
On the first day of trial, after the court denied suppression as untimely, Tineo entered an unconditional guilty plea; he was sentenced to 151 months concurrent on each count.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion by denying Tineo's suppression motion as untimely	Government: Scheduling order deadlines are enforceable; motion filed after deadline and caused no undue prejudice	Tineo: Motion timely enough given late disclosure of police statements and alleged Miranda violations; merits not reached	Court affirmed: denial not an abuse of discretion; scheduling deadline respected
Whether a straight guilty plea preserves the right to challenge pre-plea constitutional defects (here, Miranda claim)	Government: Unconditional guilty plea forfeits challenges to pre-plea suppression rulings	Tineo: Arguably could still challenge Miranda denial despite guilty plea	Court: Guilty plea forfeited the suppression claim; plea extinguished the appeal on that pre-plea defect

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes requirement to advise suspects of rights before custodial interrogation)
Blackledge v. Perry, 417 U.S. 21 (1974) (protects against vindictive prosecution; exception to forfeiture rule)
Menna v. New York, 423 U.S. 61 (1975) (double jeopardy exception to plea forfeiture)
Haring v. Prosise, 462 U.S. 306 (1983) (guilty plea generally forfeits pre-plea non-jurisdictional claims)
United States v. Gonzalez, 311 F.3d 440 (1st Cir. 2002) (unconditional plea forfeits objections and defenses)
United States v. Castro-Vazquez, 802 F.3d 28 (1st Cir. 2015) (defendant who pleads guilty at trial forfeits last-minute suppression challenges)