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Name: United States v. Crawford
Case #: 01-50633
Court: US Court of Appeals
District 9 Cir
Opinion Date: 06/21/2004
Subsequent History: Cert. den. 1/10/05

Officers received a report that “Ralphy Rabbit” had participated in an armed bank robbery in 1998, and believed “Ralphy Rabbit” was the alias used by appellant. They discovered that appellant was on parole, and had signed a “Fourth Waiver” which allowed searches of his residence without cause. Officers did not expect to find evidence of the robbery, which had occurred two years earlier, but intended to use the search as a pretext to speak to appellant about the robbery. The residence was searched while appellant sat on a couch. The officer attempted to engage him in conversation, but appellant did not give any information. Appellant then agreed to accompany officers to the police station, in order to discuss a “parole violation.” He was told he was not under arrest and was free to leave. Miranda warnings were not given. Appellant was interrogated for over an hour, and eventually confessed to participating in the robbery. He was subsequently indicted for and convicted of the robbery. The appellate court here affirmed. Assuming that the parole search was unlawful, the statements at issue were not made during the involuntary detention. The connection between the primarily illegality and the evidence obtained is missing. Therefore, the initial detention did not require the suppression of the later statement at the police station. Further, Miranda warnings were not required because there was no custodial interrogation. Nor did the fact that the police used a deceptive tactic to induce appellant to go to the station amount to coercion. Under the totality of circumstances, the confession was voluntary.