United States v. Devaney

In United States v. Devany, No. 23-10385 (5th Cir. Jan. 18, 2024) (unpublished), the Fifth Circuit affirmed the denial of the defendant’s motion to suppress statements he made while suffering “methamphetamine withdrawal and the stress of solitary confinement.”

In the district court, Devaney had moved to suppress statements he made during a police interview, arguing that his waiver of rights under Miranda v. Arizona, 384 U.S. 436 (1966) was invalid. In sum, he argued that “he was not rational at the time of the interview” because he was suffering from methamphetamine withdrawal and the stress of solitary confinement. He contended that “law enforcement violated his rights by failing to ascertain and confirm he was rational before accepting his waiver.”

In a two-page opinion, the Fifth Circuit disagreed because “[t]he sole concern of the Fifth Amendment, on which Miranda was based, is governmental coercion’. Colorado v. Connelly, 479 U.S. 157, 170 (1986).” Devaney had identified no “cognizable, official coercion,” so his claim failed.

The Fifth Circuit also rejected Devaney’s other claim, which was foreclosed. The court has previously rejected the argument that the primary drug Guideline, USSG § 2D1.1, “is flawed and lacks an empirical basis.”