## Facts

- Charles Thomas Dickerson was questioned by federal agents about a bank robbery and made incriminating statements, including admitting involvement as the getaway driver.
- The questioning occurred while Dickerson was in custody, and the parties disputed whether he received complete and proper *Miranda* warnings before he spoke.
- Dickerson was arrested and indicted in federal court for bank robbery-related offenses.
- Dickerson moved to suppress his statements, arguing they were inadmissible because the interrogation did not comply with *Miranda v. Arizona*.
- The district court granted the motion to suppress, treating the warning problem as a *Miranda* violation and excluding the statements.
- After losing the suppression ruling, the Government sought reconsideration and asked the district court to reopen the suppression hearing to present additional testimony; the court denied reconsideration.
- The United States appealed the suppression order (and denial of reconsideration) under 18 U.S.C. § 3731.

## Issues

1. Whether 18 U.S.C. § 3731 authorizes the Government to appeal the denial of a motion to reconsider a suppression order, and thereby permits review of the underlying suppression ruling.
2. Whether the district court abused its discretion by refusing to reopen the suppression hearing to receive additional evidence offered by the Government.
3. Whether 18 U.S.C. § 3501 supersedes *Miranda* in federal prosecutions so that a voluntary confession is admissible even if the warnings were technically deficient.
4. Whether Dickerson’s statements were voluntary under § 3501 and therefore admissible.

## Decision

- The court held it had appellate jurisdiction under 18 U.S.C. § 3731 to review the denial of reconsideration and, in doing so, to review the underlying suppression order.
- The court applied abuse-of-discretion review to the refusal to reopen the suppression hearing and found no basis to overturn that discretionary call.
- The court held that 18 U.S.C. § 3501 (enacted in 1968) provides the rule for admitting confessions in federal court and that the statute’s voluntariness standard, rather than *Miranda*’s exclusionary rule, controlled this federal case.
- Applying § 3501, the court concluded Dickerson’s statements were voluntary under the totality of the circumstances and should not have been suppressed based solely on a technical *Miranda* defect.
- The court reversed the suppression order and remanded for further proceedings.

## Legal Principles

- 18 U.S.C. § 3731 is read broadly to allow Government appeals from orders suppressing evidence; an appeal from denial of reconsideration may bring the underlying suppression ruling before the court of appeals.
- A district court’s decision whether to reopen a suppression hearing is reviewed for abuse of discretion.
- Under 18 U.S.C. § 3501, a confession is admissible in federal court if voluntary; the presence or absence of warnings is a factor in assessing voluntariness rather than an automatic bar to admission.
- Congress may set evidentiary and procedural rules for federal courts; on the Fourth Circuit’s analysis in this case, § 3501 could displace judge-made prophylactic rules for admitting confessions in federal prosecutions.

## Conclusion

The Fourth Circuit reversed the district court’s suppression of Dickerson’s custodial statements, holding that § 3501 supplied the governing admissibility standard in federal court and that Dickerson’s confession was voluntary and therefore admissible despite an asserted *Miranda* warning defect; the case was remanded for continued proceedings (a holding later rejected by the Supreme Court in *Dickerson v. United States*, 530 U.S. 428 (2000)).


United States v. Dickerson, 166 F.3d 667 (1999)