In United States v. Woodson, No. 20-10443 (Apr. 13, 2022) (Branch, Grant, Brasher), the Court affirmed Mr. Woodson’s convictions and sentence.
Mr. Woodson was charged with offenses relating to child pornography and extortionate interstate communications. A jury found him guilty on all counts, and he was sentenced to 50 years’ imprisonment followed by a life term of supervised release.
On appeal, he first challenged the district court’s denial of his motion to suppress statements he made to police without the benefit of Miranda warnings. Approximately 15 officers arrived at the home Mr. Woodson shared with his family, including his brother Brandon, to execute a search warrant. Mr. Woodson was asleep when the officers entered his bedroom, handcuffed him, and escorted him to the living room, where he joined his family. Officers then interviewed Brandon outside of the home, inside a parked police van. They determined that he was unlikely to be the culprit. Mr. Woodson agreed to talk with officers next. He was uncuffed and followed officers to the same parked police van. He sat in the front passenger seat, with one detective in the driver’s seat and another detective in the back seat. Mr. Woodson was advised that he was not under arrest, that he was not charged with a crime, and that they were talking voluntarily. He was not, however, read the Miranda warnings. Mr. Woodson eventually confessed to the crimes alleged, and after less than an hour, the discussion concluded, and he was escorted back inside the home. He was not arrested until nearly eight months later.
Mr. Woodson argued that his statements should have been suppressed because his discussion with law enforcement had been a custodial interrogation that required Miranda warnings. The Court disagreed. The Court first clarified that the determination of custody under Miranda depends entirely on the objective circumstances of the interrogation, which are assessed from the perspective of the reasonable innocent person. As such, the Court found the lower court’s reliance on the subjective beliefs of Brandon regarding his interactions with law enforcement to be erroneous. Because the custody test is objective, courts do not consider subjective beliefs, even those of others who are interrogated. The Court then concluded that a reasonable person in Mr. Woodson’s position would have felt free to terminate the interview and leave, though it recognized that “the question may be close here.” In support, the Court noted that Mr. Woodson was advised he was not under arrest, not charged with a crime, and that his conversation was voluntary; he was not handcuffed and sat in the front passenger seat of the police van.
Additionally, even if a reasonable person in Mr. Woodson’s position would not have felt free to terminate the interview and leave, the interview environment did not present the serious danger of coercion that a custodial interview entails. First, any display of police control and authority that occurred earlier when officers executed the search warrant was irrelevant to the determination of whether the subsequent interview was custodial. Additionally, Mr. Woodson was not whisked away to the police station, but instead remained outside his home, in clear view of his neighbors. Finally, he was not entirely cut off from his normal life–he quickly returned to it. That officers threatened to expose Mr. Woodson to his boss if he lied to them and the hour-long duration of the interview did not tip the scale in Mr. Woodson’s favor.
Mr. Woodson also challenged his sentence on procedural and substantive grounds, which the Court rejected.
Judge Brasher filed a concurrence, noting that, in his view, the lower court did not err in considering the testimony of Brandon as part of the totality of circumstances of the Miranda custody determination. This is so because he was neither the suspect nor the police; rather he was an innocent third-party who testified about his impression of the scene.