United States v. Woods

Officer Mardigian stopped Jermaine Woods (defendant) for speeding. Woods did not immediately comply with Mardigian’s directives and said he did not have a license, so Mardigian decided to arrest Woods for driving without a license. Ultimately, police forced Woods to the ground and handcuffed him. During a pat-down search incident to the arrest, Mardigian felt a hard lump in Woods’s pocket and asked Woods, “What is in your pocket?” Woods responded, “I’m bogue,” which is slang for possessing something illegal. Mardigian asked Woods whether he had a gun or drugs, and Woods responded that it was a gun. Mardigian asked Woods where the gun was, and Woods responded that it was in his car. The hard lump in Woods’s pocket was Woods’s keys. After placing Woods in a police car, Mardigian peered into Woods’s car and saw a handgun lying on the floor. Mardigian then searched the entire car and seized the gun and crack cocaine. Police did not give Woods Miranda warnings at any point during his stop or arrest. Woods was charged with drugs and firearms offenses, and the district court denied Woods’s motion to suppress his “bogue” statement and the contraband. Woods pleaded guilty and then appealed the denial of his motion to suppress, alleging that Mardigian’s questioning without issuing Miranda warnings violated his Fifth Amendment rights.