United States v. Steven Carter
1990 WL 121154, 910 F.2d 1524 (1990)
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Rule of Law:
A confession is considered voluntary and admissible even if police deceptively fail to alleviate a suspect's fears about the potential prosecution of a loved one, provided there is no evidence of explicit threats or promises and the suspect's will was not overborne by psychological coercion.
Facts:
- On January 9, 1989, a robber struck two tellers and stole over $14,000 from the Acme Continental Credit Union in Chicago.
- On January 20, 1989, the same credit union was robbed again in a similar manner.
- During the second robbery, a witness pursued the robber and recorded his car's license plate number.
- The license plate was traced to Steven Carter, who had purchased the car with cash a few days after the first robbery.
- On February 16, 1989, police arrested Carter at his parole office; his pregnant fiancée, Lashan Riggins, who was with him, was also taken to the police station for questioning.
- After Carter was identified in a lineup by multiple witnesses, he asked Detective Steve Glynn if Riggins would be charged.
- Glynn responded that he did not know, despite knowing at that time that the assistant state's attorney had no intention of prosecuting Riggins.
- Shortly after this conversation, Carter confessed to both robberies, asking that his parole officer be told he had cooperated.
Procedural Posture:
- Steven Carter was charged in a federal indictment with two counts of bank robbery.
- Prior to trial in the U.S. District Court, Carter filed a motion to suppress his confessions as involuntary.
- The district court held a suppression hearing and denied Carter's motion.
- Following a trial, the jury found Carter guilty on both counts.
- The district court sentenced Carter as a career offender under the Sentencing Guidelines.
- Carter appealed his convictions and sentence to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does police conduct that fails to dispel a suspect's fear that his pregnant fiancée will be charged with a crime, without making an explicit threat, render the suspect's subsequent confession involuntary?
Opinions:
Majority - Crabb, Chief District Judge
No, such police conduct does not render the confession involuntary. For a confession to be involuntary, the defendant's will must have been overborne by coercive police conduct. Here, the appellate court deferred to the trial court's factual finding that Detective Glynn did not explicitly threaten Carter that his fiancée, Riggins, would be charged if he did not confess. While Glynn's failure to truthfully inform Carter that Riggins would not be charged created an 'undercurrent of deceit,' it did not rise to the level of coercion necessary to make the confession involuntary. The court reasoned that Glynn never indicated that Carter's cooperation would lead to Riggins's release. Furthermore, Carter's request for his parole officer to be notified of his cooperation, rather than a request for Riggins's release, suggested his motive was to gain leniency for himself, not to protect her. Therefore, under the totality of the circumstances, the confession was a product of a rational intellect and free will.
Analysis:
This case illustrates the high threshold for demonstrating psychological coercion sufficient to render a confession involuntary. It draws a crucial line between police making explicit threats concerning a suspect's loved ones, which is coercive, and police using deceptive tactics that merely play on a suspect's pre-existing fears, which may be permissible. The decision heavily reinforces the principle of appellate deference to a trial court's credibility determinations, making it exceptionally difficult to challenge a voluntariness ruling that hinges on conflicting testimony. This precedent gives law enforcement considerable leeway to use subtle psychological pressure during interrogations, so long as they avoid direct threats or promises.
