United States v. Willix, 8:16-cr-00211

DEA/USPS agents arranged delivery of a mail parcel containing ~4 pounds of methamphetamine to an address; Willix arrived in a minivan and said he expected the package but refused to sign for it.
After the delivery attempt, officers (wearing "Police" vests) approached Willix; he fled, was chased, physically struggled with officers, twice tried to unholster an officer’s gun, and two officers were injured.
Local police impounded and conducted a warrantless search of Willix’s minivan, finding evidence linking him to the parcel.
Willix was arrested and, after receiving Miranda warnings, agreed to a post-arrest interview with DEA agents and made inculpatory statements.
At pretrial suppression hearings, Willix argued (1) the vehicle search violated the Fourth Amendment, (2) his post‑Miranda statements were involuntary or induced by promises, and (3) the jury should receive a special instruction narrowing the meaning of “inflict” under 18 U.S.C. § 111(b).
The district court denied suppression and refused the specialized instruction; the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument (Willix)	Defendant's Argument (Government)	Held
Warrantless search of minivan	Search was unlawful; not a valid inventory or search-incident-to-arrest	Search was lawful under automobile exception (and district relied on inventory)	Affirmed: automobile exception provided probable cause to search the operational vehicle
Post-arrest statements	Statements induced by promises (agents said they'd convey truthfulness and thus would not charge for drug crimes); waiver not knowing/voluntary	Willix was Miranda‑advised, waived rights, and agents made no promises; any statements were voluntary	Affirmed: waiver was valid; no promise shown that vitiated Miranda waiver
Jury instruction on “inflict” in § 111(b)	“Inflict” requires direct, intentional physical causation (so jury should get a narrow definition)	Statute is unambiguous; court’s literal instruction sufficed; no controlling Eleventh Circuit precedent adopting a narrower definition	Affirmed: no error in refusing specialized instruction given facts (violent struggle causing injuries)

United States v. Caraballo, 595 F.3d 1214 (11th Cir.) (affirming searches under automobile exception)
United States v. Tamari, 454 F.3d 1259 (11th Cir.) (elements for automobile-exception searches)
United States v. Willis, 759 F.2d 1486 (11th Cir.) (collective knowledge doctrine for probable cause)
United States v. Franklin, 323 F.3d 1298 (11th Cir.) (flight is indicative of wrongdoing)
United States v. Barbour, 70 F.3d 580 (11th Cir.) (standards for Miranda waiver voluntariness)
United States v. Ramirez-Chilel, 289 F.3d 744 (11th Cir.) (credibility determinations in suppression hearings)
United States v. McGarity, 669 F.3d 1218 (11th Cir.) (district court’s discretion in jury charges)
United States v. Zabawa, 719 F.3d 555 (6th Cir.) (discussion of narrow/direct-causation interpretation of "inflict")
United States v. Jackson, 310 F.3d 554 (7th Cir.) (contrast on causation theory for “inflict”)
South Dakota v. Opperman, 428 U.S. 364 (U.S.) (inventory search principles)
United States v. Bosby, 675 F.2d 1174 (11th Cir.) (limits on inventory searches; cannot be pretext for investigation)