United States v. Williams
2012 U.S. App. LEXIS 9988
2d Cir.2012Background
- Williams and cousin were arrested in a Bronx apartment after ATF/NYPD search; four guns recovered and Williams admitted ownership.
- Williams later transported to a station house; Miranda rights were read and waived before a detailed confession.
- An earlier, unwarned statement at the apartment did not occur after Miranda; it concerned ownership of guns.
- District court suppressed the station house confession as the product of a deliberate two-step interrogation barred by Seibert, relying on Capers to require a legally justifiable delay.
- The Government appealed, arguing no deliberate two-step strategy and that any questioning could be justified by public safety and totality of circumstances.
- The Second Circuit reversed, holding no deliberate two-step and that the station house confession could be admitted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the station-house confession obtained via deliberate two-step interrogation? | Government argues no deliberate two-step strategy occurred. | Williams contends the questioning was a planned two-step Seibert-style protocol. | No deliberate two-step found; waiver and voluntariness upheld. |
| Did public safety justify the apartment questioning in lieu of warnings? | Government maintains public safety justified initial questioning. | Williams argues questioning was designed to elicit incriminating statements without warnings. | Court did not need to decide if public safety justified it; nonetheless, no deliberate strategy was shown. |
| Should Capers control whether the second, warned confession is admissible? | Government contends Capers allows consideration of totality of evidence to assess deliberateness. | Williams argues Capers requires suppressing the station house confession. | Capers does not require automatic suppression; totality of evidence weighs against deliberateness. |
| Are the station house statements voluntary under Elstad despite any unwarned questioning earlier? | Government contends voluntary and non-coercive under Elstad. | Williams argues prejudicial interrogation tainted voluntariness. | Statements were voluntary; waiver was knowing and voluntary. |
Key Cases Cited
- Seibert v. United States, 542 U.S. 600 (U.S. 2004) (articulates five-factor test for determining Deliberate two-step interrogations)
- Capers, 627 F.3d 470 (2d Cir. 2010) (totality-of-evidence standard to assess deliberateness; burden on government)
- Moore, 670 F.3d 222 (2d Cir. 2012) (public safety rationale can negate deliberate strategy; analysis under Capers)
- Carter, 489 F.3d 528 (2d Cir. 2007) (Seibert framework applied in identifying deliberate two-step coercion)
- Elstad, 470 U.S. 298 (U.S. 1985) (establishes voluntariness framework after voluntary unwarned statement)
- Estrada, 430 F.3d 606 (2d Cir. 2005) (recognizes context of public safety and non-deliberate questioning)