United States v. Williams, No. 15-10475 (9th Cir. 2016)
Annotate this CaseAfter defendant was arrested for murder, the district court suppressed defendant's statement under Miranda v. Arizona. A sheriff's deputy had asked defendant whether he was a member of a criminal street gang after he invoked his right to an attorney. The court held that when a defendant charged with murder invokes his Miranda rights, the government may not in its case-in-chief admit evidence of the prisoner’s unadmonished responses to questions about his gang affiliation. Accordingly, the court affirmed the suppression order.
Court Description: Criminal Law. Affirming the district court’s suppression order, the panel held that when a defendant charged with murder invokes his Miranda rights, the government may not admit in its case-in- chief evidence of the defendant’s unadmonished responses to prison officials’ questions about his gang affiliation. Dissenting, Judge Kleinfeld wrote that the “public safety” and “booking” exceptions to Miranda make the defendant’s answer to a gang question admissible.
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