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Police not responsible for moral and psychological pressures to confess

Facts

David Devaney, Sr., challenges: the denial of his motion to suppress statements made to law-enforcement officers for conspiracy to possess with intent to distribute 50 grams or more of methamphetamine, in violation of 21 U.S.C. § 846. He was found guilty and sentenced to 480 months. Regarding the denial of the suppression motion, Devaney contends his waiver under Miranda v. Arizona, 384 U.S. 436 (1966), was invalid because he was not rational at the time of the interview, caused by his methamphetamine withdrawal and the stress of solitary confinement. He asserts law enforcement violated his rights by failing to ascertain and confirm
he was rational before accepting his waiver. The 5th affirmed.

Analysis

Contrary to Devaney’s contention, the sole concern of the Fifth Amendment, on which Miranda was based, is governmental coercion. See SCOTUS Colorado v. Connelly, 479 U.S. 157 (1986). Indeed, the Fifth Amendment privilege is not concerned with moral and psychological pressures to confess emanating from sources other than official coercion. Devaney identifies no cognizable, official coercion.

 

https://www.ca5.uscourts.gov/opinions/unpub/23/23-10385.0.pdf