United States v. Dickerson

166 F.3d 667 (4th Cir. 1999)

Facts

In response to the Supreme Court's decision in Miranda v. Arizona, 384 U.S. 436, 16 L. Ed. 2d 694, 86 S. Ct. 1602 (1966), the Congress of the United States enacted 18 U.S.C.A. § 3501 (West 1985), with the clear intent of restoring voluntariness as the test for admitting confessions in federal court. The United States Department of Justice has steadfastly refused to enforce the provision. D confessed to robbing a series of banks in Maryland and Virginia. D was indicted by a federal grand jury on one count of conspiracy to commit bank robbery, three counts of bank robbery, and three counts of using a firearm during and in relation to a crime of violence. The district court specifically found that D's confession was voluntary for purposes of the Fifth Amendment, it nevertheless suppressed the confession because it was obtained in technical violation of Miranda. P appealed.