US v. Pressley: In 2012 Pressley (and others) were under investigation for drug trafficking. Officers went to talk to Pressley and wound up interrogating him in one of their vehicles, causing him to make incriminating statements. Those statements played a large part in the Pressley’s eventual trial, where he was convicted on 13 counts related to drug trafficking. Pressley later filed a 2255 motion arguing that his trial counsel had been ineffective for failing to move to suppress the statements he made, claiming they were given without Miranda warnings. The district court denied Pressley’s motion without a hearing.
On appeal, the Fourth Circuit ordered the case remanded with instructions for the district court to hold an evidentiary hearing. Pressley’s version of events surrounding the statements, which must be accepted as true in the absence of an evidentiary hearing, showed that a motion to suppress would have had “some substance,” as it suggested the questioning was done in custody and thus Miranda warnings were required. However, the record did not show whether Pressley relayed those facts to his trial counsel or whether counsel made a strategic decision not to file a motion to suppress. As a result, the case had to return to the district court for an evidentiary hearing. However, the court did go ahead and hold Pressley was prejudiced by the use of his statements at trial (assuming they should have been suppressed in the first place).
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