United States v. Williamson
181 F. Supp. 3d 41
D.D.C.2014Background
- Defendant Jeff Henry Williamson was arrested; at the scene he was handcuffed and had suitcases with his property.
- No Miranda warnings were given at the scene; warnings were delivered only after transport to the police station.
- While Agent Christie patted Williamson down, an exchange occurred in which Williamson made a violent statement referencing gouging out eyes and cutting out a trachea (disputed exact wording).
- Law enforcement testimony conflicted on sequence: Deputy Mustapha testified the defendant spoke first and then Agent Christie asked “why are you so mad?”; an FBI Report showed the question preceding the statement.
- Defendant moved to suppress the violent statement as the product of custodial interrogation without Miranda warnings; the Government argued the statement was spontaneous (not interrogation) and thus admissible.
- The Court found credibility in favor of Deputy Mustapha, concluded the sequence was too close to call on spontaneous utterance versus interrogation, and—preferring to err for the defendant—granted the renewed motion to suppress.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a violent statement made while in custody must be suppressed because it was elicited by police questioning without Miranda warnings | Williamson: Statement was elicited by police (interrogation) and must be suppressed absent Miranda warnings | Government: Statement was a spontaneous, volunteered remark not in response to interrogation, so Miranda does not apply | Court: Suppression granted — sequence too close to call, defendant in custody, question “why are you so mad?” not routine booking; court favors defendant and suppresses statement |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (Miranda rights apply to custodial interrogation)
- Pennsylvania v. Muniz, 496 U.S. 582 (Booking-question and spontaneous-statement exceptions to Miranda)
- Rhode Island v. Innis, 446 U.S. 291 (Interrogation includes express questioning and its functional equivalent)
- United States v. Samuels, 938 F.2d 210 (D.C. Cir.) (Volunteered statements admissible without Miranda)
- United States v. Tuten, 293 F. Supp. 2d 30 (D.D.C.) (Similar treatment of spontaneous utterances vs. interrogation)