Skip to content
Name: United States v. Barnes
Case #: 11-30107
Court: US Court of Appeals
District 9 Cir
Opinion Date: 04/18/2013

Defendant’s federal drug conviction reversed where FBI agents deliberately delayed giving Miranda warnings in an effort to induce self-incrimination. Defendant was convicted of a federal drug offense after the trial court denied his motion to suppress statements he gave to FBI agents during a custodial interrogation. Held: Reversed. Barnes was told to attend a meeting by his parole officer, at which FBI agents confronted him with evidence of drug trafficking before giving him Miranda warnings. The confrontation occurred inside a police dominated, confined environment and lasted two hours. Barnes would not have felt free to leave and was therefore in custody. The delay in providing Miranda warnings was a prohibited “two-step” interrogation. The mid-interrogation warnings, given after Barnes incriminated himself, were ineffective to ameliorate the delay in providing them. Barnes’ confession went to the heart of the prosecution case; the error was not harmless, requiring reversal.