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No. 10591531
United States Court of Appeals for the Ninth Circuit
United States v. Watson
No. 10591531 · Decided May 23, 2025
No. 10591531·Ninth Circuit · 2025·
FlawFinder last updated this page Apr. 2, 2026
Case Details
Court
United States Court of Appeals for the Ninth Circuit
Decided
May 23, 2025
Citation
No. 10591531
Disposition
See opinion text.
Full Opinion
FOR PUBLICATION
UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
UNITED STATES OF AMERICA, No. 24-1865
D.C. No.
Plaintiff - Appellee,
1:22-cr-00149-
BLW-1
v.
TYLER JAY WATSON,
OPINION
Defendant - Appellant.
Appeal from the United States District Court
for the District of Idaho
B. Lynn Winmill, District Judge, Presiding
Argued and Submitted April 22, 2025
Moscow, Idaho
Filed May 23, 2025
Before: Richard C. Tallman, N. Randy Smith, and Ryan D.
Nelson, Circuit Judges.
Opinion by Judge Tallman
2 USA V. WATSON
SUMMARY *
Criminal Law
The panel affirmed the district court’s denial of Tyler Jay
Watson’s motion to suppress incriminating statements he
made to police officers and the fruits thereof in a case in
which Watson entered a conditional guilty plea to one count
of possession with intent to distribute fentanyl.
Based on information received from a confidential
informant, a police task force in Nampa, Idaho began
investigating Watson for drug distribution. When law
enforcement learned that Watson was on parole, they
coordinated with Probation and Parole officers to conduct a
compliance search of Watson’s vehicle and residence. After
officers found methamphetamine attached to the vehicle’s
undercarriage, they drove to Watson’s residence and
conducted a search. While the search was ongoing, Watson
remained detained in an officer’s patrol vehicle parked down
the street. Another officer approached Watson in the back
of the patrol car and read Watson his Miranda
rights. Watson acknowledged his rights and stated his
willingness to cooperate. Watson then admitted he was
holding more of “the product” at his grandmother’s
home. Following Watson’s confession, officers drove to
Watson’s grandmother’s house and obtained her consent to
search her garage. Officers discovered and seized fentanyl,
methamphetamine, and cash.
*
This summary constitutes no part of the opinion of the court. It has
been prepared by court staff for the convenience of the reader.
USA V. WATSON 3
Watson argued that his supervision agreement’s
condition requiring that he cooperate with the requests of his
probation/parole officer, where cooperation includes being
truthful, created a classic penalty situation in which Watson
was compelled—under threat of parole revocation—to make
incriminating statements to law enforcement in violation of
his Fifth Amendment rights. The panel disagreed. Because
Watson’s supervision agreement required cooperation and
truthfulness with his parole officer, but not all law
enforcement officers, the panel could not conclude that a
Mirandized interrogation by police in the course of
investigating a new, separate offense was involuntarily
compelled.
COUNSEL
David J. Morse (argued), Assistant United States Attorney;
Joshua D. Hurwit, United States Attorney; Office of the
United States Attorney, United States Department of Justice,
Boise, Idaho; for Plaintiff-Appellee.
Mikela French (argued), Mike French Law PLLC, Boise,
Idaho, for Defendant-Appellant.
4 USA V. WATSON
OPINION
TALLMAN, Circuit Judge:
Based on information received from a reliable
confidential informant (“CI”), a police task force in Nampa,
Idaho, began investigating Defendant-Appellant Tyler Jay
Watson for drug distribution. When law enforcement
learned that Watson was on parole, they coordinated with
Probation and Parole (“P&P”) officers to conduct a
compliance search of Watson’s vehicle and residence. The
CI had advised officers that Watson transported drugs in
magnetized containers under his vehicle. After officers
found methamphetamine attached to the vehicle’s
undercarriage, they drove to Watson’s residence and
conducted a search. While the search was ongoing, Watson
remained detained in Officer Scott’s patrol vehicle parked
down the street. A police officer, Detective Coronado,
approached Watson in the back of the patrol car and read
Watson his Miranda rights. Watson acknowledged his
rights and stated his willingness to cooperate. Watson then
admitted he was holding more of “the product” at his
grandmother’s home. Following Watson’s confession,
officers drove to Watson’s grandmother’s house and
obtained her consent to search her garage. Officers
discovered and seized fentanyl, methamphetamine, and
cash.
Watson was charged with one count of possession with
intent to distribute fentanyl. He filed a motion to suppress
the incriminating statements he made to Detective Coronado
and the evidence seized from his vehicle and his
grandmother’s home, alleging they were the product of
Fourth and Fifth Amendment violations. Following an
USA V. WATSON 5
evidentiary hearing, the district court denied the motion,
finding that each search was constitutional and that Watson’s
admissions to Detective Coronado were not involuntarily
compelled. Watson subsequently conditionally pled guilty
and was sentenced to 188 months of imprisonment.
On appeal, Watson argues that his Agreement of
Supervision’s (“Agreement”) condition requiring that he
“cooperate with the requests of [his] probation/parole
officer,” where “[c]ooperation includes being truthful,”
created a “classic penalty situation” in which Watson was
compelled—under threat of parole revocation—to make
incriminating statements to law enforcement. We disagree.
Watson’s statements were made to a police officer, not his
P&P officer, after an adequate Miranda warning.
Because Watson’s Agreement required cooperation and
truthfulness with his parole officer, but not all law
enforcement officers, we cannot conclude that a Mirandized
interrogation by police in the course of investigating a new,
separate offense was involuntarily compelled. Accordingly,
we affirm the district court’s denial of Watson’s motion to
suppress and hold that Watson was not subject to a penalty
situation under these circumstances.
I
In May 2022, Watson was on parole supervision from
the Idaho Department of Corrections (“IDOC”) when
Nampa Police Department (“NPD”) officers and Federal
Drug Enforcement Administration (“DEA”) agents became
aware of his involvement in drug trafficking. A CI told the
interagency drug task force officers that Watson was dealing
narcotics, storing controlled substances at two different
locations, and transporting the narcotics in magnetic boxes
in and under his vehicle. After obtaining a warrant, the task
6 USA V. WATSON
force intercepted communications between Watson and his
supplier. Those communications corroborated the
information provided by the CI and led investigators to
believe that Watson was trafficking in large quantities of
fentanyl powder—enough to generate a weekly payment of
at least $15,000 to his supplier.
Upon further investigation, task force officers confirmed
with IDOC P&P officers that Watson was on parole and was
known to frequent his current registered parole residence—
his mother’s home—and his previously registered parole
residence—his grandmother’s home. Officers also learned
that Watson had signed an Agreement outlining the terms
and conditions of his parole that prohibited his use and
possession of controlled substances and waived his Fourth
Amendment rights. By signing the Agreement, Watson
consented to a search of his “person, residence, vehicle,
personal property, and other real property . . . by any agent
of IDOC or a law enforcement officer.” Another condition
in the Agreement stated:
I will cooperate with the requests of my
probation/parole officer. Cooperation
includes being truthful. If I am detained by
law enforcement, I will tell the officer(s) that
I am on felony supervision, and the name of
my probation/parole officer. I will notify my
probation/parole officer of any such contact
within 24 hours.
With the information the task force garnered during its
investigation, officers planned an operation to conduct a
traffic stop to perform a parole compliance search of
Watson’s vehicle as permitted by the Agreement.
USA V. WATSON 7
On the morning of the planned operation, officers were
briefed and surveilling Watson’s home when they watched
him depart. Officers observed Watson make a turn without
using his signal, and NPD Officer Jared Scott, who had been
briefed on the operation earlier in the day, conducted a traffic
stop. Officer Scott explained to Watson that he had been
stopped due to a failure to use a turn signal. Officer Scott
obtained Watson’s license and registration, asked some
questions to gauge Watson’s demeanor and cooperation
level, and ensured that there were no firearms or other
weapons in the vehicle. After receiving confirmation from
P&P officers that they wanted Watson’s vehicle searched,
officers detained Watson, handcuffed him, and put him in
the back of Officer Scott’s patrol vehicle while Officer Scott
and other investigators searched Watson’s vehicle.
While the vehicle search was underway, P&P Officer
Steve Landers approached Watson, who was still detained in
the back of the police cruiser. P&P Officer Landers asked
Watson whether they would find anything in Watson’s
vehicle. Watson stated they would not. Shortly thereafter,
P&P Officer Chance Nicholas arrived on the scene, told
Watson he knew about the drug investigation, and asked
Watson for the passcode to his cell phone. Watson provided
the passcode. No further interaction between P&P officers
and Watson occurred after this conversation.
While searching Watson’s vehicle, task force officers
discovered two magnetic boxes containing suspected
controlled substances attached to the vehicle’s undercarriage
below the driver’s side door. Officer Scott transported
Watson to his residence (his mother’s home), where Watson
remained in the police car while investigators searched his
residence pursuant to the Agreement. During this time, NPD
Detective Michael Coronado and two DEA agents
8 USA V. WATSON
approached Watson while he was sitting in the back of the
police car. 1 Detective Coronado read Watson his Miranda
rights, 2 and Watson confirmed that he understood his rights
and was willing to talk to officers. Detective Coronado
explained to Watson that police knew he was “holding the
product” at his grandmother’s residence on Nez Perce Street.
Watson responded, “Yeah, it’s there,” and agreed to show
Detective Coronado where it was located. The group then
drove to Watson’s grandmother’s house.
Once at the grandmother’s home, officers obtained her
consent to search the garage. During the garage search,
Detective Coronado asked Watson if he would be willing to
show investigators where the controlled substances were
located so they could avoid exposure to any fentanyl.
Watson agreed. Officer Scott escorted Watson into the
garage, and Watson showed the investigators where the
drugs and illicit drug proceeds were located. Investigators
found over four and a half kilograms of fentanyl powder,
approximately two ounces of methamphetamine, and
approximately $8,600 in drug proceeds.
1
Detective Coronado testified that he approached and interviewed
Watson about two and a half hours after the initial traffic stop occurred.
Detective Coronado also testified that no P&P officers were in the
vicinity of the patrol car at this time.
2
The district court found that Detective Coronado adequately conveyed
to Watson his rights. Detective Coronado testified that he read the
Miranda warning from a picture of a card provided by Canyon County
prosecutors, which lists an individual’s rights while in custody as
required by Miranda. Watson does not challenge the sufficiency of the
Miranda warning on appeal. Instead, he argues that even an adequate
warning was insufficient to remedy the coercive and misleading effect
of P&P officers’ involvement in the searches.
USA V. WATSON 9
II
Watson was indicted on one count of possession with
intent to distribute fentanyl in violation of 21 U.S.C.
§ 841(a)(1) and (b)(1)(A). He moved to suppress the
statements he made to the officers as well as the physical
evidence found in the vehicle and at his grandmother’s house
as violations of the Fourth and Fifth Amendments. 3 More
specifically, Watson argued that his incriminating
statements to Detective Coronado were involuntarily
compelled because his Agreement contained a condition
requiring cooperation with his parole officer. Because
failure to comply with this condition could result in
revocation of his parole, Watson argued this parole condition
created a “penalty situation” that runs afoul of the Fifth
Amendment.
The district court denied Watson’s motion to suppress.
The district court distinguished the case from Minnesota v.
Murphy, 465 U.S. 420 (1984), and United States v. Saechao,
418 F.3d 1073 (9th Cir. 2005), which addressed the
potentially coercive effect of parole conditions on
incriminating statements made to parole officers. Unlike
those cases, Watson’s incriminating statements were made
to a law enforcement officer, Detective Coronado, after a
valid Miranda warning. The district court concluded that
those “two facts, taken together, remedy the coercive effect
of the parole condition.” While acknowledging the risk of
confusion where officers rely on a parole compliance check
rather than probable cause or a warrant, the district court
found that “[t]he Miranda warning combined with the fact
that Officer Coronado is not Mr. Watson’s parole officer is
3
On appeal, Watson does not challenge the district court’s admission of
the evidence seized from his vehicle.
10 USA V. WATSON
sufficient to signal that the nature of the interaction had
changed from a parole compliance check to some kind of
investigation.”
Subsequently, Watson entered into a plea agreement in
which he agreed to plead guilty to the indictment upon the
condition that he be allowed to appeal the court’s denial of
the motion to suppress. Following the entry of Watson’s
conditional plea, the district court sentenced him to 188
months in prison and five years of supervised release.
III
The district court had jurisdiction under 18 U.S.C.
§ 3231. We have jurisdiction under 28 U.S.C. § 1291 and
18 U.S.C. § 3742(a).
IV
“We review de novo motions to suppress, and any factual
findings made at the suppression hearing for clear error.”
United States v. Negrete-Gonzales, 966 F.2d 1277, 1282 (9th
Cir. 1992). A finding of clear error requires “a definite and
firm conviction that a mistake has been made. Thus, if the
district court’s findings are plausible in light of the record
viewed in its entirety, the appellate court cannot reverse even
if it is convinced it would have found differently.” United
States v. McCarty, 648 F.3d 820, 824 (9th Cir. 2011)
(quoting Husain v. Olympic Airways, 316 F.3d 829, 835 (9th
Cir. 2002)).
V
A
On appeal, Watson argues that his incriminating
statements and the fruits thereof should be suppressed
because his Agreement required him to cooperate and be
USA V. WATSON 11
truthful with parole officers upon threat of revocation of
parole and, as a result, he was involuntarily coerced into
responding to task force questions in violation of his Fifth
Amendment rights. Watson argues that his Miranda
warning was insufficient to negate compulsion and that the
district court incorrectly emphasized that Watson’s
statements were made to Detective Coronado, not a parole
officer. Watson argues that because the Fourth Amendment
waiver condition in his Agreement permits search by “any
agent of IDOC or a law enforcement officer,” he could have
reasonably misunderstood that all of the Agreement’s
concessions are made to all law enforcement, not just parole
officers.
Watson further contends that P&P officers were
“omnipresent” throughout the search of his vehicle, his
residence (his mother’s home), his grandmother’s home, and
Detective Coronado’s questioning, leading Watson to
believe he had no choice but to “cooperate” or face
revocation of parole. He points to several facts: the search
was characterized “early and often” to Watson as a P&P
compliance search; P&P instructed Officer Scott to detain
Watson and search his car; P&P Officer Nicholas—
Watson’s parole supervisor—spoke with Watson, took his
phone, and asked for his password; P&P Officer Landers
arrived on scene and spoke with Watson, asking him what
“we” would find in the car and telling him, not asking, that
“we” were going to search his house; no one from P&P gave
Watson his Miranda warnings; and P&P Officer Landers is
so embedded within NPD as the liaison between the P&P
and the drug task force that he keeps his office there. Watson
maintains that the fact that it was Officer Coronado, rather
than a P&P officer, who Mirandized and questioned him
does not remedy the coercive impact of P&P’s involvement,
12 USA V. WATSON
which “muddied the water” and led Watson to believe that
his Agreement required he comply with Detective
Coronado’s request to talk for fear of losing his liberty.
On appeal, the government argues that the district court
properly denied Watson’s motion to suppress because the
circumstances surrounding his incriminating statements did
not create a “classic penalty situation.” The government
argues that Watson’s Agreement required truthfulness to his
probation/parole officer, not any law enforcement officer,
and that his post-Miranda incriminating statements to law
enforcement occurred after the interaction had shifted from
a parole compliance check to a drug investigation. Further,
the government notes that Watson’s Agreement stated that if
he was detained by law enforcement, he agreed to tell the
officer(s) he was on felony supervision and provide his
parole officer’s name—notably omitting any requirement to
cooperate with or be truthful to law enforcement. The
government argues that Watson’s statements were not
involuntarily compelled under penalty of revocation because
Watson’s P&P officer was not involved in eliciting his
incriminating statements: P&P officers were not present
when Detective Coronado Mirandized Watson, his
statements were not made to P&P officers, and P&P officers
only interacted with Watson during the traffic stop.
B
The Fifth Amendment’s privilege against self-
incrimination generally applies only to those who “claim it.”
Saechao, 418 F.3d at 1077 (quotation omitted). However,
this general rule does not apply when an individual is
“denied the free choice to admit, to deny, or to refuse to
answer.” Id. This can occur when the government creates a
situation where “an individual’s refusal to answer
USA V. WATSON 13
incriminating questions subjects him to a penalty.” Id. In a
“penalty situation,” the Fifth Amendment becomes self-
executing. Murphy, 465 U.S. at 435–36. In other words, “if
the state, either expressly or by implication, asserts that
invocation of the privilege would lead to revocation of
probation . . . the failure to assert the privilege would be
excused, and the probationer’s answer would be deemed
compelled and inadmissible in a criminal prosecution.” Id.
at 435.
In the probationary [or parole] context, this
means that although the state is permitted to
require a probationer to “appear and discuss
matters affecting his probationary status,” the
probationer may not be required under threat
of revocation of probation to respond to
“questions put to [him], however relevant to
his probationary status, [that] call for answers
that would incriminate him in a pending or
later criminal proceeding.”
Saechao, 418 F.3d at 1077 (quoting Murphy, 465 U.S. at
435).
The Supreme Court has instructed that a “general
obligation to appear and answer questions truthfully [does]
not in itself convert [a defendant’s] otherwise voluntary
statements into compelled ones.” Murphy, 465 U.S. at 427.
For that reason, not every probation condition requiring
truthfulness or cooperation creates a penalty condition.
Rather,
in order for a court to determine whether a
probationer is subject to a penalty situation, it
14 USA V. WATSON
“must inquire whether [his] probation
conditions merely required him to appear and
give testimony about matters relevant to his
probationary status or whether they went
further” by taking “the extra, impermissible
step” of requiring him “to choose between
making incriminating statements and
jeopardizing his conditional liberty by
remaining silent.”
Saechao, 418 F.3d at 1077–78 (quoting Murphy, 465 U.S. at
436).
Murphy and Saechao illustrate the line between a
permissible probation/parole condition and an impermissible
penalty situation. In Murphy, the Supreme Court held that a
condition requiring the defendant to “be truthful with his
probation officer in all matters” did not render an otherwise
voluntary statement involuntary because it did not require
him to answer his probation officer’s inquiries. 465 U.S. at
436–37. “On its face, Murphy’s probation condition
proscribed only false statements; it said nothing about his
freedom to decline to answer particular questions[.]” Id. at
437. The Court concluded that Murphy could not have been
“deterred from claiming the privilege by a reasonably
perceived threat of revocation.” Id. at 439.
In contrast, we have found a penalty situation where the
probation condition required the probationer to “promptly
and truthfully answer all reasonable inquiries” because
staying silent could result in revocation of probation.
Saechao, 418 F.3d at 1075. Unlike Murphy, Saechao “was
compelled by threat of penalty to answer the probation
officer’s inquiry” because the terms of his probation
compelled him to truthfully answer all inquiries. Id. at 1078.
USA V. WATSON 15
The key differentiating feature between the probation
conditions in Saechao and Murphy was whether the
probationer was free to remain silent without risking
revocation of parole. Murphy’s probation condition
proscribed false statements only, leaving him free to remain
silent so long as he was truthful when he spoke. Murphy,
465 U.S. at 437. In contrast, Saechao’s probation condition
expressly penalized the refusal to answer a question—failure
to answer a relevant inquiry regarding the conditions of his
probation would have justified revocation of probation.
Saechao, 418 F.3d at 1078. In other words, a probation
condition requiring answers to all relevant inquiries implies
that a defendant may not invoke his Fifth Amendment right
to remain silent without facing a penalty—here, revocation
of probation or parole. See id. at 1079.
The district court reasoned that Watson’s parole
condition requires more than truthfulness (as in Murphy) but
does not explicitly require answers to all inquiries (as in
Saechao). Seeing the three conditions side-by-side is useful:
- Murphy’s condition required him to “be
truthful with the probation officer ‘in all
matters.’” Murphy, 465 U.S. at 422;
- Saechao’s condition required him to
“promptly and truthfully answer all
reasonable inquiries by the Department of
Correction or County Community
Correction Agencies.” Saechao, 418 F.3d
at 1075;
- Watson’s condition required him to
“cooperate with the requests of [his]
probation/parole officer” and stipulated
16 USA V. WATSON
that “[c]ooperation includes being
truthful.”
We have not yet addressed whether a condition requiring
“cooperation”—as opposed to explicitly requiring answers
to inquiries as in Saechao—creates an impermissible penalty
situation. 4 We do not decide that question here. Watson’s
incriminating statements were made to a law enforcement
officer and therefore could not be penalized pursuant to the
Agreement.
C
The district court held that Watson was not subject to the
“classic penalty situation” because his incriminating
statements were made to Detective Coronado, a law
enforcement officer after he administered Miranda
warnings. Those two facts, the district court reasoned,
distinguished Watson’s case from Saechao. We agree. The
district court relied on the following factors to support its
decision to deny the motion to suppress:
1. NPD Detective Coronado adequately
conveyed to Watson his Miranda rights;
4
Watson’s Agreement also did not expressly or impliedly state he would
be subject to revocation of parole if he violated the conditions. Rather,
the Agreement stated that Watson understood that his failure to comply
with the conditions “may result in the submission of a report of violation
to [his] sentencing/paroling authority.” This language is different
from Saechao, which provided that “failure to comply with any of the
conditions was grounds for arrest, revocation of probation, or
modification of conditions.” 418 F.3d at 1075. Although we need not
reach this issue, the permissive language here does not clearly invoke a
threat of revocation.
USA V. WATSON 17
2. the lack of recording or written waiver
did not affect the adequacy of the
Miranda warning;
3. Watson’s parole conditions mandated
cooperation only “with requests of [his]
probation/parole officer, not all law
enforcement”;
4. Watson’s statements were to law
enforcement, not a P&P officer; and
5. “[t]he Miranda warning combined with
the fact that [Detective] Coronado is not
Mr. Watson’s parole officer [was]
sufficient to signal that the nature of the
interaction had changed from a parole
compliance check to some kind of
investigation.”
Additional factors support the district court’s conclusion
that Watson’s admissions were not involuntarily compelled.
Most notably, there was no further interaction between the
P&P officers and Watson after the initial traffic stop. P&P
Officer Landers testified that during the search of Watson’s
residence, neither he nor P&P Officer Nicholas spoke to
Watson or approached Officer Scott’s patrol car in which
Watson was detained. P&P Officer Landers stated that he
did not communicate with or approach Watson because a
pending investigation was ongoing, and he wanted to avoid
“creat[ing] the illusion” that P&P officers were forcing
Watson to make incriminating statements. P&P Officer
Landers confirmed that it was his standard practice to avoid
any communication with probationers/parolees after
incriminating evidence is found in order to avoid coercion or
the appearance thereof.
18 USA V. WATSON
To be sure, during the vehicle stop, search, detention,
and residence searches, the division of labor between P&P
and other law enforcement personnel was not always clear.
As the district court noted, Officer Scott told Watson he was
being detained and his vehicle searched at the direction of
probation and parole. P&P Officer Landers used the
pronoun “we” when he told Watson, “After we’re done
searching your vehicle, we’re going to take you back to your
house and we’re going to search your house.” Later,
Watson’s interview with Detective Coronado occurred in the
back of the patrol car where Watson had been initially
detained for a parole compliance check. The interview
occurred while officers were searching Watson’s residence,
ostensibly as part of that compliance check. Officer Scott,
who originally told Watson he was acting pursuant to P&P’s
request, escorted Watson through the various stops until he
arrived at the police station. Overall, and as the district court
emphasized, officers “muddied the water” between the
parole compliance check and the investigation of drug
trafficking by conducting the vehicle and residence searches
as a parole compliance check instead of obtaining a warrant
based on ample probable cause.
The district court also noted that the integrated nature of
this task force operation may have made it difficult for
Watson to distinguish between which officers he was
required to cooperate and be truthful with and which officers
he had a Fifth Amendment right to refuse interrogation. 5
And, as the district court observed, any confusion Watson
5
This is not to say that P&P officers need hesitate before cooperating
with local law enforcement or contacting them for assistance. We
acknowledge the benefits derived from such cooperation, particularly
where P&P officers have reason to believe their safety may be at risk
when conducting compliance checks in potentially hazardous situations.
USA V. WATSON 19
may have had was “entirely of the government’s own
making.” But none of this changes the critical point:
Watson’s Agreement penalized only his failure to respond to
parole officers, and he made his incriminating statement in
response to a question by a law enforcement officer, not a
parole officer.
Watson also argues that he was never advised that failure
to speak with law enforcement would not result in parole
revocation. In support of this argument, Watson relies on
this line in Saechao: “Moreover, the state did not advise him
that ‘it would not, [or] legally could not, revoke probation
for refusing to answer questions calling for information that
would incriminate in separate criminal proceedings.’”
Saechao, 418 F.3d at 1081 (quoting Murphy, 465 U.S. at
438). But Watson’s situation was entirely different than
Saechao’s. Saechao’s incriminating statements (admitting
he had a hunting rifle in his home, in violation of his
probation agreement) were made in response to questioning
by his probation officer—not another law enforcement
officer. Id. at 1075; see also id. (noting Saechao’s probation
conditions required responses to probation officers). During
questioning, the probation officer twice reminded Saechao
that his probation conditions required him to “promptly and
truthfully answer all reasonable inquiries” and that failure to
comply could result in probation revocation. Id. at 1081.
Only within this context did we note that Saechao was not
specifically advised that he could “refus[e] to answer
questions calling for information that would incriminate
[him] in separate criminal proceedings.” Id. at 1078
(quoting Murphy, 465 U.S. at 438).
Contrary to Watson’s argument, there is no legal
requirement for P&P officers to affirmatively inform a
probationee/parolee that refusing to speak to law
20 USA V. WATSON
enforcement would not jeopardize his probation/parole
status. Nothing in Watson’s Agreement stated he was
required to speak, cooperate, or be truthful with law
enforcement. The Agreement required only that, if detained
by law enforcement, Watson would “tell the officer(s) that
[he is] on felony supervision, and the name of [his]
probation/parole officer.” Additionally, that Watson was
properly Mirandized immediately prior to his incriminating
statements further undermines his argument that he was
never told he could remain silent during police questioning
without facing the possibility of parole revocation. Neither
of the probationers in Saechao nor Murphy were “in
custody” or provided their Miranda warnings, which
informed Watson of his ability to remain silent.
Ultimately, despite the risk of confusion possible in an
integrated operation like this one, the district court properly
concluded that Watson’s admissions were made voluntarily.
Watson was never told that refusing to answer officers’
questions would result in the revocation of his parole or
another penalty. Cf. Garrity v. New Jersey, 385 U.S. 493,
494, 500 (1967) (statements obtained under explicit threat of
removal from office were coerced and inadmissible). Before
questioning him, Detective Coronado read Watson his
Miranda rights and Watson stated that he understood those
rights. When Detective Coronado asked if the officers
would find drugs at his grandmother’s house, Watson said,
“Yeah, it’s there.” Watson then agreed to show the officers
where the drugs were hidden in his grandmother’s garage.
Watson’s statements about the drugs and the resulting
seizure were thus legitimate fruits of his Mirandized
interrogation by law enforcement.
USA V. WATSON 21
***
Watson was not subject to a penalty situation because
nothing in Watson’s Agreement required that he speak,
cooperate, or be truthful with law enforcement; he was
properly Mirandized immediately prior to his incriminating
statements, stated he understood his rights, and agreed to
cooperate; and he was never told that refusing to answer
officers’ questions would result in the revocation of his
parole or any other penalty. Because Watson’s statements
were not involuntarily compelled under penalty of parole
revocation, the district court properly denied Watson’s
motion to suppress.
AFFIRMED.
Plain English Summary
FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT UNITED STATES OF AMERICA, No.
Key Points
01FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT UNITED STATES OF AMERICA, No.
02Lynn Winmill, District Judge, Presiding Argued and Submitted April 22, 2025 Moscow, Idaho Filed May 23, 2025 Before: Richard C.
03WATSON SUMMARY * Criminal Law The panel affirmed the district court’s denial of Tyler Jay Watson’s motion to suppress incriminating statements he made to police officers and the fruits thereof in a case in which Watson entered a conditional
04Based on information received from a confidential informant, a police task force in Nampa, Idaho began investigating Watson for drug distribution.
Frequently Asked Questions
FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT UNITED STATES OF AMERICA, No.
FlawCheck shows no negative treatment for United States v. Watson in the current circuit citation data.
This case was decided on May 23, 2025.
Use the citation No. 10591531 and verify it against the official reporter before filing.