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United States v. Feliz

United States Court of Appeals for the First Circuit
794 F.3d 123 (2015)


Facts

Victor Feliz (defendant) was charged with possession of a firearm in furtherance of a drug-trafficking crime and possession with intent to distribute cocaine base. Feliz signed two written confessions regarding his alleged offenses. Before his trial, Feliz moved to suppress the confessions as involuntary, asserting that officers had threatened to deport his mother and place his siblings into state custody unless he confessed. At a pretrial hearing before a magistrate judge, the United States (plaintiff) offered testimony from two police officers, who said that Feliz had made the confessions freely. The defense offered testimony from Feliz and his mother, who said that officers had dictated Feliz’s confessions to him and that Feliz signed the confessions only after being threatened. The magistrate judge recommended that Feliz’s confessions be suppressed. However, the federal district court held a new hearing and excluded the defense’s testimony about the officers’ threats as hearsay. Without that testimony, the court said that there was no evidence of coercion and admitted Feliz’s confessions into evidence. Feliz was eventually convicted, and he appealed to the United States Court of Appeals for the First Circuit.

Rule of Law

Issue

Holding and Reasoning (Lynch, J.)

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