United States v. Wright
233 F. Supp. 3d 165
D.D.C.2017Background
- Defendant Tyrone Wright was charged by superseding indictment with three counts of bank robbery after Premier Bank (April 20 and April 21) and TD Bank (April 21) were robbed and surveillance images circulated to police.
- A teller and a library police officer identified Wright from surveillance photos; officers located and approached Wright at the Northwest One library on April 21.
- Officers asked his name, told him he was a person of interest, and asked him to step outside; Wright cooperated initially but later refused to go to headquarters and was handcuffed and patted down.
- Items seized at the library included keys, cigarettes, a cell phone, red‑stained tissues, and a robbery note; dye‑stained money and Wright’s clothing/shoes (stuffed with money) were later collected at the station.
- Wright was transported in handcuffs to the station, read Miranda warnings, signed a waiver, and gave some statements on video; government does not intend to use statements in its case‑in‑chief but may use them for impeachment.
- Wright moved to suppress both physical evidence and statements, claiming Fourth Amendment and voluntariness/Miranda violations; the court held an evidentiary hearing and denied suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held | |
|---|---|---|---|---|
| Lawfulness of warrantless arrest | Wright: detention/arrest unlawful; initial stop exceeded Terry bounds | Govt: officers had probable cause based on surveillance photos, ID by teller and library officer, red dye marks, and other corroboration | Court: Probable cause existed from the outset; warrantless arrest lawful | |
| Seizure/search of person and items | Wright: items seized from person/library/restroom violated Fourth Amendment | Wright: detention prior to search converted to unlawful seizure | Govt: search was incident to lawful arrest; items from person and pockets permissible; no reasonable expectation of privacy in public restroom debris | Court: Physical evidence admissible as search incident to lawful arrest; Fourth Amendment claim denied |
| Miranda and admissibility of pre‑custodial/library statements | Wright: statements taken without Miranda and under coercion; not voluntary | Govt: asking name and similar questions are routine/booking and not interrogation; other statements not used in case‑in‑chief | Court: Miranda not required for routine ID/name; statements at library voluntary and admissible for impeachment; no coercion shown | |
| Voluntariness of stationhouse statements and waiver | Wright: shackling, restraints, deprivation, intimidation overbore will; waiver invalid | Govt: Miranda warnings given, video shows no threats, he received water, he refused some questions—indicative of voluntariness | Court: Waiver and statements were voluntary; may be used for impeachment |
Key Cases Cited
- United States v. Robinson, 414 U.S. 218 (search incident to lawful arrest doctrine)
- Chimel v. California, 395 U.S. 752 (scope of search incident to arrest)
- Arizona v. Gant, 556 U.S. 332 (search incident to arrest limits)
- Devenpeck v. Alford, 543 U.S. 146 (probable cause standard for arrest)
- Maryland v. Pringle, 540 U.S. 366 (warrantless public‑place felony arrest)
- Wong Sun v. United States, 371 U.S. 471 (fruits doctrine)
- Rawlings v. Kentucky, 448 U.S. 98 (search timing relative to arrest)
- Lego v. Twomey, 404 U.S. 477 (government burden to prove voluntariness for impeachment use)
- Dickerson v. United States, 530 U.S. 428 (Miranda and waiver analysis)
- Schneckloth v. Bustamonte, 412 U.S. 218 (totality‑of‑circumstances voluntariness test)