Motion to suppress a confession; Voluntariness; Whether defendant’s incriminating statements were “coerced”; The “coercion test”; United States v Rigsby

The court held that defendant-Jacobs’s motion to suppress his incriminating statements should have been denied where, under the totality of the circumstances, there was no evidence that the statements were “involuntary.” Thus, it reversed the district court’s ruling granting his motion. When Jacobs heard that there was an arrest warrant issued for him in connection with a drug store robbery, he turned himself in. The warrant was issued after the police found his fingerprint on a package of gum he left at the scene. At the police station, a detective (A) asked Jacobs a few general questions and then read him his Miranda rights, which Jacobs signed. Jacobs initially denied that he had committed the robbery, but eventually made several incriminating statements, explaining how he committed it and his actions afterward. At trial, he moved to suppress his incriminating statements to A, alleging that they were involuntary because A’s questioning was “impermissibly coercive.” After the district court granted the motion, the government brought an interlocutory appeal. Applying the Rigsby coercion test, the court first held that A did not “engage in any objectively coercive conduct.” It noted that he always spoke “in a conversational tone, offered Jacobs food and drink, never brandished a weapon or handcuffs, and did not threaten or use violence.” Additionally, the interview was only about two hours long, and he gave Jacobs a break from questioning. While he threated to get a search warrant, “a threat to perform a lawful search isn’t objectively coercive.” Further, A’s conduct was not sufficient to “overbear Jacobs’s will.” The court noted that he received Miranda warnings and had previous experience with the police. The court rejected Jacobs’s claim that the threat to get a warrant for his father’s house was so coercive that it made his statements involuntary. It disagreed with the district court’s characterization of A’s statements as a threat to “‘ransack’” the father’s home, especially where he specified that he would only be looking for the clothes Jacobs wore during the robbery. Thus, the court held that, under the totality of the circumstances, A did not use coercion to obtain Jacobs’s incriminating statements. Reversed and remanded.