United States v. Hallford
| Decision Date | 06 May 2015 |
| Docket Number | Criminal No. 13–0335 RJL |
| Citation | 103 F.Supp.3d 1 |
| Parties | United States of America, v. Joseph Daniel Hallford, Defendant. |
| Court | U.S. District Court — District of Columbia |
Elizabeth Harper Danello, T. Patrick Martin, Thomas A. Gillice, U.S. Attorney's Office for the District of Columbia, Michael Justin Friedman, U.S. Department of Justice, Washington, DC, for United States of America.
Jonathan Jeffress, Federal Public Defender for D.C., Washington, DC, for Defendant.
May 6th, 2015 [## 10, 11]
Defendant Joseph Daniel Hallford (“Hallford” or “defendant”) seeks to suppress the statements—and the physical evidence obtained as a result of those statements—that were made when he was questioned by agents of the United States Secret Service while involuntarily committed to a local psychiatric hospital, United Medical Center (“UMC”), on November 6, 2013. SeeMot. to Suppress Statements Taken in Violation of the Constitution [Dkt. # 10]; Mot. to Suppress Evidence Seized in Violation of the Constitution [Dkt. # 11]. Upon careful consideration of defendant's motions, the Government's oppositions thereto, the testimony and arguments of counsel at the evidentiary hearings,1the parties' supplemental pleadings, and the relevant law, the Court GRANTS both motions.2
On November 6 of 2013, two U.S. Secret Service agents dressed in casual clothes assigned to the protective intelligence squad interviewed the defendant at UMC in Washington, D.C., where he was being involuntarily committed for a mental health evaluation. Tr. June 5, 2014 at 5:6–9, 10:10–16, 41. He was at UMC pursuant to a referral from the emergency room staff at the George Washington Hospital (“GW”). Id.at 40. The defendant, a native of Alabama, who was participating in the Million Mask March,3had voluntarily checked himself into the emergency room at GW earlier that day in the hope of getting certain medications necessary to deal with the extreme pain he was experiencing as a result of his hemophilic condition. Id.at 116:2–4, 114:14–17.
The agents who conducted the interview at UMC amazingly made noeffort before summoning him for an interview to determine either his medical status, or the status of his psychological condition, prior to requesting the interview. They were, nevertheless, under the distinct impression (1) that he had bragged to GW personnel about taunting a White House Police Officer to shoot him during the Million Mask March, and (2) that he was in such physical distress while at GW that he had threatened to strike one of their physicians if he didn't get a particular pain medicine he needed. Id.at 37:18–23, 38:4–7. As to his psychiatric condition, the agents also admitted knowing that he had been committed to UMC against his will and had not yet had a preliminary psychiatric evaluation by their staff. Id.at 40:2–12.
Towards the end of an hour long interview, during which they deceptively told defendant he would only be questioned about his threatening remarks at GW, and afterconcluding that the defendant did not pose a threat to anyone that the Secret Service protects or any of its employees, they decided to question him about whether he owned any weapons. Id.at 65:13–22, 100:18–101:23. The agents, of course, had no reason to believe that this first-time visitor to Washington, D.C., was aware that it was illegal to possess a weapon in the District of Columbia. Nevertheless, without administering any Mirandarights or warnings, they inquired about both his gun ownership and where in specific they were located. Id.at 159:9–18.
The defendant, not surprisingly, readily admitted to owning a pistol, a couple rifles, and a shotgun. When asked where they were being stored, he said they were being stored at his home in Alabama, but then corrected himself shortly thereafter and acknowledged that they were in the trunk of his car, which was parked somewhere in the District of Columbia near the National Mall. Id.at 71:2–13. He also admitted to having other items in the trunk that might “look bad.” Id.at 71:14–18. One of those items apparently was the disassembled components of a so-called “Molotov cocktail.” Id.He said, when asked, that he kept the weapons in his trunk for personal protection because he had been previously been jumped by a gang in Alabama. Id.at 72:14–73:7.
As a result of these admissions, defendant's car was located and searched without a warrant by U.S. Park Police. Id.at 85:4–12. There police officers found the pistol, the handgun, ammunition, and the various ingredients of a possible “Molotov cocktail” that are the basis of the charges in this case.Id.; see alsoGov't's Omnibus Opposition, at 7–8 [Dkt. # 12] (the “Opposition” or “Opp.”) (listing contents of car).
Defendant contends he was in custody at the time of this interview and, therefore, seeks to suppress his statements to the agents, due to their failure to provide him with Mirandawarnings. SeeMot. to Suppress Statements Taken in Violation of the Constitution [Dkt. # 10]. In addition, defendant seeks to suppress the physical evidence seized from his car on the theory that his medical and psychological conditions combined that night were such that his statements were involuntarily given. Mot. to Suppress Evidence Seized in Violation of the Constitution [Dkt. # 11]. For the following reasons I agree with the defendant's position as to each issue.
The suppression of defendant's statements without the benefit of Mirandawarnings is, in this case, a relatively straightforward question turning on whether he was in custody at the time of his interview. See Miranda v. Arizona,384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). To determine whether a person is in custody for Mirandapurposes, courts ascertain whether, in light of “the objective circumstances of the interrogation,” Stansbury v. California,511 U.S. 318, 322–23, 325, 114 S.Ct. 1526, 128 L.Ed.2d 293 (1994), a “reasonable person [would] have felt he or she was not at liberty to terminate the interrogation and leave,” Thompson v. Keohane,516 U.S. 99, 112, 116 S.Ct. 457, 133 L.Ed.2d 383 (1995). The Supreme Court has held that the determination of custody hinges on whether a person is subjected to treatment that renders him, in practical terms, in custody. Berkemer v. McCarty,468 U.S. 420, 440, 442, 104 S.Ct. 3138, 82 L.Ed.2d 317 (1984). This inquiry is evaluated through the prism of how a reasonable man in the defendant's position would have understood his situation, i.e.,would a reasonable man have understood his situation to be a restraint of his freedom of movement akin to a formal arrest?
In this ease, there are clearly a number of factors that would have led a reasonable person in the defendant's position to believe he was in custody. Defendant was, in fact, in official custody by virtue of his involuntary commitment. Indeed, he had been physically restrained when he was transferred from GW to UMC against his will. June 5, 2014 Tr. at 127:8–17. At UMC, the defendant was summoned by agents for an interview, not asked if he would submit to an interview. Indeed, the defendant was never told he could refuse to answer questions or suspend the interview at any time. Moreover, the defendant was escorted to the interview room at UMC, both coming and going, by a phalanx of hospital staff. The room itself was a secure room that had locked doors limiting access into and out of the room. Tr. June 5, 2014, at 42:2–24. In addition, shortly after entering the room, the agents took a photograph of the defendant in a hospital gown without his permission. Id.at 150:23–151:6. And, of course, he was interrogated without any warning of his Mirandarights, or even the right to stop the interview at any time. Id.at 158:13–159:18.
Under the totality of the circumstances, any reasonable person would have believed that he was not free to leave or terminate the interview. See Thompson v. Keohane,516 U.S. 99, 112, 116 S.Ct. 457, 133 L.Ed.2d 383 (1995). Thus, because no Mirandawarnings were given, the defendant's statements to those agents that evening must be suppressed. The remaining question, however, is a closer question, i.e.,whether the defendant's statements were obtained involuntarily.
The Supreme Court has made it clear that evidence obtained in the absence of Mirandawarnings is not ordinarily suppressible unless obtained involuntarily. See United States v. Patane,542 U.S. 630, 640, 124 S.Ct. 2620, 159 L.Ed.2d 667 (2004) . The Government, of course, bears the burden of demonstrating the voluntariness of those statements by a preponderance of the evidence. Lego v. Twomey,404 U.S. 477, 489, 92 S.Ct. 619, 30 L.Ed.2d 618 (1972); United States v. Wiggins,509 F.2d 454, 461 (D.C.Cir.1975).
The Supreme Court has also been clear regarding the involuntariness inquiry that it is not limited to claims that the police conduct in question was inherently coercive. See Miller v. Fenton,474 U.S. 104, 110, 106 S.Ct. 445, 88 L.Ed.2d 405 (1985)(quoting Ashcroft v. Tennessee,322 U.S. 143, 154, 64 S.Ct. 921, 88 L.Ed. 1192 (1944). For example, it is not necessary that the police employed restraints, manacles, or other such instrumentalities of inherent coercion. The focus, rather, is whether the defendant's will was overborne by the totality of the circumstances surrounding his statements. See Dickerson v. United States,530 U.S. 428, 434, 120 S.Ct. 2326, 147 L.Ed.2d 405 (2000). Ultimately, the Supreme Court has said, it comes down to a weighing of the circumstances of pressure versus the power of resistance. Id.Courts thus should look at the defendant's conditions of detention, the attitude of the police toward the defendant, ...
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United States v. Hallford
...issued a written opinion on May 6, 2015, repeating its oral findings and conclusions with a few embellishments. See United States v. Hallford,103 F.Supp.3d 1 (D.D.C.2015). The government asks us to disregard the court's written opinion because it was handed down four months after the govern......
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United States v. Hallford
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...committed patients have noted such factors as central to the custody analysis. Compare United States v. Hallford, No. 13–0335(RJL), 103 F.Supp.3d 1, 1–2, 2015 WL 2128680, at *3 (D.D.C. May 6, 2015) (where defendant, who was questioned in his hospital gown, was not asked if he would submit t......