United States v. Donovan New

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding agents did not restrict a defendant’s freedom of movement when any physical restrictions were the result of the defendant’s hospitalization and agents did not impose additional restraints
• holding when a suspect is hospitalized and cannot leave, the inquiry for custody is whether a reasonable person would have felt like he was at liberty to terminate the interrogation
• noting the “division of authority on whether a patient has a reasonable expectation of privacy in a hospital room” and collecting authority
• holding defendant was not in custody when he made statements to law enforcement while “confined to [a hospital] bed” in part because “the agent . . . placed no constraints on [defendant’s] movement,” “no force” was used, and the atmosphere was not “police dominated”
• no custody found where the defendant was confined to his hospital bed in a neck brace but no restraint was imposed by the interrogating officer
• no custody found where the defendant was confined to his hospital bed in a neck brace but no restraint was imposed by the interrogating officer

Source: CourtListener parenthetical corpus (CC0).