Evidence Suppression

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7^th Circuit Court of Appeals

Case Name: United States of America v. Jeremy Outland

Case No.: 22-1485

Officials: Ripple, Scudder, and St. Eve, Circuit Judges.

Focus: Evidence Suppression

Officer Weiss of Springfield obtained a search warrant for Outland’s person and residence, specifically looking for heroin and drug paraphernalia. During a traffic stop, another officer found drug paraphernalia, informed Outland of his Miranda rights, and started taking him to a DEA facility. However, Outland collapsed, with his face and coat covered in a white substance identified as heroin. The officer promptly rushed Outland to the emergency room where he was unresponsive upon triage at 10:46 a.m. Medical staff immediately administered medications, and by approximately 11:30 a.m., Outland passed swallowing tests. Although he remained drowsy and experienced apneic episodes, he generally displayed alertness and orientation, showing significant improvement in his mental state. While awaiting an available ICU bed, Outland was placed on a Narcan drip. Throughout the process, hospital staff described Outland as alert, awake, and oriented at regular intervals. Officer Weiss arrived around 1:00 p.m., where the officer assigned to Outland informed him that Outland had requested to speak with Weiss. Outland confirmed his identity and date of birth, after which Weiss read him his Miranda rights and ensured his comprehension. Subsequently, Outland made several self-incriminating statements regarding his involvement in heroin trafficking.

Based on these events, Outland was charged with the distribution and conspiracy to distribute 100 grams or more of heroin under 21 U.S.C. 841(a)(1), 841(b)(1)(B)–(C), 846. However, during the subsequent legal proceedings, Outland’s argument that his intoxicated state rendered his statement involuntary and that he was unable to knowingly and willingly waive his Miranda rights due to the effects of medications was rejected by the district court upon remand. The denial of his motion to suppress was affirmed by the Seventh Circuit.

Affirmed.

Decided 07/11/23

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