United States v. Williams
2010 U.S. Dist. LEXIS 132763
S.D.N.Y.2010Background
- Williams was arrested on October 20, 2009, after a search of Apartment 3C, 1200 College Avenue, Bronx, yielded four firearms and ammunition.
- The investigation traced a firearms trafficker known as 'Alabama' to Alabama and to a possible NY sale, with misidentifications involving Phillip Scott/Phillip Burroughs.
- Agent D'Antonio's warrant affidavit contained three inaccuracies and several omissions about sources, timelines, and CI interactions; magistrate issued the search warrant later that day.
- Williams admitted ownership of the guns during an initial interrogation at the College Avenue apartment, before Miranda warnings were given.
- At the 44th Precinct, after Miranda rights were read, Williams waived rights and gave statements; the government later sought to admit both rounds of statements.
- Judge denied a Franks hearing, concluding the inaccuracies/omissions were not material to probable cause; but granted suppression of the post-arrest statements under Capers due to deliberate two-step interrogation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Franks hearing eligibility | Williams argues false statements/omissions require Franks relief. | Williams contends material inaccuracies compromised probable cause. | Denied; no Franks hearing. |
| Probable cause after corrections | Corrected affidavit would still fail probable cause due to key omissions. | Corrected affidavit would still show probable cause. | Probable cause remains; evidence seized allowed. |
| Post-arrest statements suppression | Miranda warnings at the 44th Precinct cured any taint from unwarned pre-warning statement. | Two-step interrogation, Capers framework; taint not cured; statements should be suppressed. | Post-arrest statements suppressed. |
Key Cases Cited
- United States v. Gates, 462 U.S. 213 (1983) (probable cause review with deference to magistrate, plus Franks considerations)
- United States v. Leon, 468 U.S. 897 (1984) (Franks framework for false statements/omissions in warrants)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause standard in warrant affidavits)
- United States v. Capers, 627 F.3d 470 (2d Cir. 2010) (deliberate two-step interrogation and curative measures under Capers)
- United States v. Carter, 489 F.3d 528 (2d Cir. 2007) (Elstad/Seibert framework for post-warning statements)
- Oregon v. Elstad, 470 U.S. 298 (1985) (two-stage interrogation; admissibility of second statement after warning)
- Missouri v. Seibert, 542 U.S. 600 (2004) (two-stage interrogation cautionary framework)