U.S. v. Outland

Dist. Ct. did not err in denying defendant’s motion to suppress inculpatory statements defendants made to police during interrogation of defendant that took place at hospital, even though defendant argued that he had not knowingly and intelligently waived his Miranda rights, under circumstances where he had been given Narcan before interrogation to counteract drug overdose that had occurred in squad car. Dist. Ct. could properly find that although defendant’s overdose may have had some impact on defendant’s cognitive capacity, it did not cause defendant to lose his ability to understand what was going on in his interactions with police. Moreover, defendant’s medical records indicated that he was mentally alert at least one hour prior to interrogation, and Dist. Ct. could properly credit officer’s testimony that defendant appeared to be alert, coherent and articulate at time of Miranda waiver. Moreover, audio recording, as well as defendant’s reference to Miranda warnings some forty minutes after they were given supported finding that defendant’s waiver was knowing and intelligent.