U.S. v. Wilkes
When ruling on whether a defendant's post-arrest statement is voluntary, a court may consider the characteristics of the defendant, the conditions of interrogation and the conduct of law enforcement officials. The defendant moved to suppress statements and alleged that the police did not warn him about his right to remain silent when he was in police custody and was interrogated about involvement with drugs. The government objected that the defendant received a Miranda warning and that his post-arrest statement was voluntary, because the defendant, a mature adult who comprehends English, did not appear to suffer from a mental disability or to be under the influence of illegal substances. A defendant's confession, to be admissible, must be voluntary. There was no evidence that the defendant was mistreated, restrained for a lengthy period or deprived of sanitary facilities, food, sleep or water. The defendant failed to establish his alleged confession was coerced. "The evidence does not support a finding [of] involuntariness," wrote the court, "on the basis of the conditions of [the defendant's] detention, despite the fact that he was not represented by counsel at the time he made the statement." The court denied the defendant's motion to suppress.