United States v. Shetler

Exculpatory confessions obtained by an illegal search and seizure can not be used as evidence unless the government can prove that the confession was obtained by legal means.

After an anonymous tip was received stating that Shetler was using and manufacturing methamphetamine at his residence, DEA agents went to his home and did an initial sweep of his garage. Finding items associated with the manufacturing of methamphetamine, the agents made warrantless searches of the home and garage yielding further items. Shetler was arrested and confessed to methamphetamine use and production. Shetler appealed his conviction arguing that the district court committed error in denying his motion to suppress his confession. The district court found that the statements should not be suppressed, as they were “sufficiently the product of the initial legal search of the garage.” The Ninth Circuit held that there was no evidence to support this conclusion, as there was no evidence in the record demonstrating that they did not also confront him with the evidence seized from the illegal searches. Further, the government did not produce evidence to demonstrate that the answers Shetler gave to the questions were not induced or influenced by the illegal search or illegally obtained evidence. REVERSED and REMANDED.