United States v. Stewart & Delegal

After jointly participating in a bank robbery in Cleveland, Tennessee, Ronnie Lee Stewart (defendant), Rodney Fred Delegal (defendant), Beacher Drell Roach, and Benjamin Leavern Wells, went their separate ways. After the FBI learned that Roach had participated in the robbery, an agent asked Roach to audio record a conversation with Stewart about the robbery. During the conversation between Roach and Stewart, Stewart implicated himself as a participant. Stewart was then arrested. While in jail Stewart implicated himself again in the robbery to a fellow inmate, Roderick Stafford. Stafford then informed government agents of the conversation. Meanwhile, Kentucky police officers arrested Delegal on state stolen vehicle charges. At the time of his arrest, and in the presence of FBI Agent Dan Brennan, Delegal was advised of his Miranda rights. After a Kentucky grand jury indicted Delegal for auto theft, Agent Brennan learned that Delegal was also a suspect in the Tennessee bank robbery. Brennan then re-advised Delegal of his Miranda rights and questioned him about the bank robbery during which Delegal confessed to taking part in. Thereafter, Stewart and Delegal were indicted on federal charges relating to the bank robbery. Delegal filed a motion in U.S. District Court to suppress his confession to Brennan. The district court denied his motion and trial commenced on August 14, 1990. All of the confessions and evidence were admitted. Stewart and Delegal were convicted and they appealed.