United States v. Chadwick
In United States v. Chadwick, 999 F.2d 1282 (8th Cir. 1993), the defendant was indicted by a federal grand jury for various drug offenses. Id. at 1283-84.
A federal agent went to the defendant's home to interview him. At the outset of the interview, the agent advised the defendant of his Miranda rights and obtained a written waiver. Id. at 1284.
The defendant later sought to suppress any incriminating statements made during the interview, contending, inter alia, that his waiver was invalidated by the agent's post-waiver statement that the defendant's cooperation would "'help'" him. Id. at 1286.
The federal district court agreed and suppressed the statements. Id. at 1286.
The Eighth Circuit reversed, concluding that the agent's "statement that Chadwick's cooperation would 'help' him could not have had any impact on Chadwick's decision to waive his Miranda rights, since the waiver had occurred earlier." Id.
The court was satisfied that the agent's statement "did not in any way influence the waiver." Id.