U.S. v. Outland

Ct. of Appeals remanded case back to Dist. Ct. for determination as to whether defendant's post-arrest, inculpatory statements to police must be suppressed, where Dist. Ct., in denying defendant's motion to suppress said statements, found only that defendant's statements were voluntary. Record showed that: (1) two hours after defendant had arrived unconscious at hospital due to heroin overdose, police officer gave defendant Miranda warnings; and (2) defendant agreed to talk to officer and subsequently made incriminating statements about his heroin dealing. In his motion to suppress said statements, defendant argued that he was so intoxicated so as to render his statements involuntary, and that he was unable to voluntarily and knowingly waive his Miranda rights based upon medications he was under at time of police questioning. Remand was required, since Dist. Ct. failed to make any finding as to whether defendant knowingly and intelligently waived his Miranda rights before interview began. Moreover, while record supported finding that defendant's statements to officer were voluntary, mere fact Miranda warning was given and accused made non-coerced statement is insufficient to demonstrate valid waiver of Miranda rights.