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United States v. Ruhl

United States District Court, D. Minnesota

June 23, 2017

United States of America, Plaintiff,
v.
Jared Clifford Ruhl, Defendant.

          ORDER ADOPTING IN PART AND REJECTING IN PART REPORT AND RECOMMENDATION

          Wilhelmina M. Wright United States District Judge

         This matter is before the Court on the April 26, 2017 Amended Report and Recommendation (R&R) of United States Magistrate Judge Franklin L. Noel, (Dkt. 48), and the United States' objection to the R&R, (Dkt. 49). The United States objects to the R&R's recommendation to grant Defendant Jared Clifford Ruhl's motion to suppress his statements to Detective Schultz. Because the Court concludes that Ruhl was not in custody when he was interviewed by Detective Schultz, the Court rejects the R&R's conclusion that Ruhl's statements to Detective Schultz must be suppressed. The Court adopts the R&R's remaining conclusions.

         BACKGROUND

         The Indictment in this case charges Defendant Jared Clifford Ruhl with conspiracy to distribute heroin, distribution of heroin, possession with intent to distribute heroin, unlawful possession of a firearm, unlawful possession of ammunition, and possession of a firearm in furtherance of a drug trafficking crime.

         The investigation underlying these charges began when Ruhl called 911 after he returned to his hotel room at the Quality Inn in Eagan, Minnesota, and found an adult male on the floor and unresponsive. Detective Sergeant John Collins and Sergeant Matt Ondrey of the Eagan Police Department arrived at the hotel, and Ruhl spoke with each of them.

         Sometime thereafter, Detective Darrin Schultz arrived and asked Ruhl to accompany him to an unoccupied hotel room nearby for an interview. The hotel room door was closed during the interview, and Ruhl was not physically restrained. The interview lasted approximately 37 minutes and was recorded by Detective Schultz. During his questioning, Detective Schultz told Ruhl, “Right now, you're a witness, but with that said, if there's anything that you're not telling us, or you have anything to hide, you probably shouldn't talk to me.” Detective Schultz also advised Ruhl, “if you did anything wrong, you probably shouldn't tell me, and that's perfectly your right, you can ask me to walk out the door, okay?” It is undisputed that Ruhl was not given Miranda warnings during the interview. Ruhl was not arrested at the conclusion of the interview, but he was arrested the next day when he returned to the hotel to retrieve some of his belongings.

         Ruhl filed several pretrial motions, including a motion to suppress the statements he made to Detective Schultz, Detective Sergeant Collins, and Sergeant Ondrey; a motion to suppress all evidence found during a search of his car, hotel room, and cell phones; and a motion for a hearing pursuant to Franks v. Delaware, 438 U.S. 154 (1978). The magistrate judge issued an R&R that recommends granting Ruhl's motion to suppress his statements to Detective Schultz and denying Ruhl's remaining motions. The R&R concludes that Detective Schultz's interview with Ruhl was a custodial interrogation that required Miranda warnings, which were not given. The R&R also recommends (1) denying Ruhl's motion to suppress evidence and for a Franks hearing, (2) denying Ruhl's motion to suppress evidence obtained during searches of his hotel room, vehicle and cell phones, and (3) denying Ruhl's motion to suppress statements Ruhl made to Detective Sergeant John Collins and Sergeant Matt Ondrey. The United States objects only to the recommendation to suppress Ruhl's statements to Detective Schultz. Neither party objects to the R&R's remaining conclusions. Ruhl filed a response to the United States' objection.

         ANALYSIS

         I. United States' Objection to the R&R

         The United States objects to the R&R's recommendation to grant Ruhl's motion to suppress his statements to Detective Schultz. The Court reviews this determination de novo. See 28 U.S.C. § 636(b)(1); Fed.R.Civ.P. 72(b)(3); LR 72.2(b)(3); Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996) (per curiam).

         Miranda warnings must be given only if a defendant is subjected to an interrogation in police custody. United States v. Nguyen, 608 F.3d 368, 374 (8th Cir. 2010). A person is in custody for Miranda purposes when there is a formal arrest or when a law enforcement officer subjects that person to a “restraint on freedom of movement of the degree associated with a formal arrest.” California v. Beheler, 463 U.S. 1121, 1125 (1983) (internal quotation marks omitted). In making this determination, the “only relevant inquiry” is how a reasonable person in the defendant's position would have understood the situation. United States v. Czichray, 378 F.3d 822, 826 (8th Cir. 2004) (quoting Berkemer v. McCarty, 468 U.S. 420, 442 (1984)). The following six factors generally are considered when determining whether a person was in custody for Miranda purposes:

(1) whether the suspect was informed at the time of questioning that the questioning was voluntary, that the suspect was free to leave or request the officers to do so, or that the suspect was not considered under arrest; (2) whether the suspect possessed unrestrained freedom of movement during questioning; (3) whether the suspect initiated contact with authorities or voluntarily acquiesced to official requests to respond to questions; (4) whether strong arm tactics or deceptive stratagems were employed during questioning; (5) whether the atmosphere of the questioning was police dominated; or, (6) whether the suspect was placed under arrest at the termination of the questioning.

United States v. Griffin, 922 F.2d 1343, 1349 (8th Cir. 1990). Although the first three factors tend to weigh against, and the remaining three tend to support, a finding that the individual was in custody, the factors are not exhaustive and should not be applied mechanistically. Czichray, 378 F.3d at 827. The ultimate inquiry is whether the individual was restrained as though under formal arrest. Id. at 828.

         Here, although Ruhl was not expressly advised that he was free to leave, Ruhl was told at the time of questioning that he was free to end the interview. Detective Schultz advised Ruhl, “if you did anything wrong, you probably shouldn't tell me, and that's perfectly your right, you can ask me to walk out the door, okay?”[1] Ruhl stated that he understood “100 percent.” Ruhl initiated contact with authorities by calling 911 when he found an adult male unresponsive in his hotel room. The interview was conducted in a vacant hotel room with the door closed, but Ruhl was not otherwise restrained during the interview. And there is no indication that Detective Schultz used strong-arm tactics at any time during the interview. Although there were several police officers at the hotel, the interview was not conducted in a police-dominated ...


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