Self-incriminating Statements Held to be "Spontaneous"

U.S. v. Yepa, 2017 WL 3014352 (7/17/17) (NM) (Published) - The 10th rejects arguments that Mr. Yepa's self-incriminating statements during a search of his person pursuant to a warrant resulted from interrogation and upholds the district court's ruling that they were spontaneous. Although officers asked a number of questions that elicited statements from Mr. Yepa, the court thinks these were just neutral follow-up questions intended to clarify spontaneous volunteered statements. The court says reasonable officers would not think their responses would be likely to result in incriminating statements despite Mr. Yepa's fatigue, intoxication, and high level of emotional stress. The court concludes that the officers' queries "did nothing to draw Defendant out" regarding the murder they were investigating.