Three days after his arrest by local police on state narcotics charges, Pedro Alvarez-Sanchez confessed to the Secret Service that federal reserve notes found in his home were counterfeit. When he was subsequently charged with the federal offense of possession of counterfeit currency, Alvarez defended himself by claiming that the delay between his arrest on state charges and his presentment on the federal charge rendered his confession inadmissible. Alvarez cited 18 U.S.C. Section 3501(c), which pronounced separate charge-based confessions inadmissible if obtained after the first six hours of detention. On appeal from a reversal of a district court's decision to uphold the confession, the Supreme Court granted the United States certiorari.

Question:

Does federal statute 18 U.S.C. Section 3501(c), declaring separate charge-based confessions inadmissible if obtained after the first six hours of detention, apply to suspects that are held only on state or federal charges?

Conclusion:

No. In a unanimous decision, the Court held that the provisions of the federal statute in question do not apply to suspects being held solely on state charges. The Court explained that no delay is said to occur until the suspect is arrested and detained for a federal crime. The six-hour period only begins to expire from the point of a suspect's federal arrest and charging. In this case, Alvarez-Sanchez was presented before a federal judge within six hours of his arrest on a federal counterfeit charge. The fact that he was held for some two and a half days prior has no bearing on his federal status under the statute since he was detained on state and local charges only during this time.

Decisions

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 18 U.S.C. 3501

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