A jury convicted Cami Braden of participating in a conspiracy to obtain methamphetamine from suppliers in Utah and transport it to Wyoming for resale. The case was essentially a cake walk for the prosecutor because the government had testimony from Braden's co-conspirators and Braden's own confession.
Not so fast, Braden argued to the Tenth Circuit Court of Appeals. Braden claimed that the confession should be suppressed because she was under the influence of methamphetamine when she made her confession for methamphetamine-related crimes. The Tenth Circuit, however, was not buying what Braden was selling - namely, her mental impairment argument.
Last week, the Tenth Circuit affirmed Braden's conviction, noting that the Braden's Miranda waiver was not automatically rendered invalid simply because she consumed alcohol or drugs prior to the interrogation.
Let's parse that out, shall we?
Here, the district court found that Braden told the interrogating officers she had used methamphetamine eight to ten hours earlier, and denied that she was under the influence of the drug during the meeting. The district court also noted that Braden was "calm, lucid, well-spoken and responded appropriately to questions throughout the interview." In other words, Braden's words and actions defeated her mental impairment defense before she could even assert it.
The Tenth Circuit Court of Appeals relies on United State v. Burson when evaluating whether a waiver is invalid due to mental impairment. The Burson test requires the court to look to the totality of the circumstances to determine whether the waiver was made "with a full awareness of both the nature of the right being abandoned and the consequences of the decision to abandon it." Here, the appellate court found that there was no evidence that the district court committed clear error in its determination that Braden knew what she was doing when she waived her Miranda rights.
We don't understand why suspects confess outside of a plea bargain, but we also don't understand why people use meth. (Maybe Braden is telling the truth, and she really didn't have the capacity for a Miranda waiver during the police interrogation.) Regardless of who is correct in this case, the Tenth Circuit looks to the totality of the circumstances in mental impairment confession suppression cases.
If you're representing a similarly-situated client who appeared lucid when she confessed to a crime under the influence of drugs or alcohol, your best bet may be to avoid trial and negotiate a plea bargain.
- U.S. v. Braden (Tenth Circuit Court of Appeals)
- How Miranda Really Works (FindLaw)
- Does Coercing a Confession Violate the Fifth Amendment Right Against Self-Incrimination (FindLaw)
- Self-Incrimination: Miranda Waivers and Invocations (FLETC)