United States v. Aaron Fein

CourtCourt of Appeals for the Sixth Circuit
DecidedFebruary 11, 2021
Docket20-1224
StatusUnpublished

This text of United States v. Aaron Fein (United States v. Aaron Fein) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Aaron Fein, (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0088n.06

Case No. 20-1224

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Feb 11, 2021 UNITED STATES OF AMERICA, ) DEBORAH S. HUNT, Clerk ) Plaintiff-Appellee, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE WESTERN DISTRICT OF AARON WILLIAM FEIN, ) MICHIGAN Defendant-Appellant. )

Before: SILER, GIBBONS, and KETHLEDGE, Circuit Judges.

SILER, Circuit Judge. Defendant Aaron William Fein entered a conditional plea to one

count of making a false statement to a federal officer. He now challenges the district court’s denial

of his motion to suppress incriminating statements he made to law enforcement officers on two

separate occasions. He also challenges his sentence for various reasons. We affirm.

I.

Offense Conduct. In April 2018, U.S. Customs and Border Protection officers conducted

an inspection of Fein’s vehicle upon attempted re-entry into the United States after he was refused

entry into Canada. They discovered notes concerning pipe bombs, remote triggering devices, and

a checklist of components used to assemble a remote detonated explosive device. Several months

later, FBI agents and a Michigan State Police bomb squad discovered such components when they

searched Fein’s bedroom. Subsequently, the FBI opened an investigation of Fein and entered him Case No. 20-1224, United States v. Fein

into the National Instant Check System (“NICS”), which would alert law enforcement if he

attempted to purchase a firearm.

Over the next several months, Fein repeatedly attempted to buy and rent semiautomatic

pistols, assault rifles, and ammunition. FBI agents interviewed him about these efforts multiple

times. After he was denied at a shooting range, his behavior caused Kent County Sheriff’s Office

to file a petition in probate court to have Fein involuntarily hospitalized. The probate court agreed

that Fein suffered from a mental illness and represented a danger to himself and others.

Consequently, he was hospitalized for several days. Upon release, the court ordered Fein to

continue outpatient treatment and medication and prohibited him from possessing firearms.

Fein violated the court’s order when he drove to Ann Arbor, Michigan to rent a

semiautomatic assault rifle and attend a weapon training. The next day, on April 19, 2019,

Michigan State Police stopped and detained Fein for violation of the probate court order and turned

him over to FBI agents. While in transport, Fein participated in a post-Mirandized interview,

where he falsely stated that he had not possessed or fired a firearm the day before.

On May 2, 2019, GPS monitoring showed Fein was at Home Depot, where he bought a

vise. The FBI suspected that Fein was going to use the vise to convert an eighty percent lower

AR-15 into a complete AR-15. The following day, officers took Fein into custody for previously

making false statements to the FBI during the April 19 interview. Despite Fein’s assertion that

there were no firearms or firearm parts in the house, a search revealed an AR-15 assembly parts

kit.

Later, Fein’s previous cellmate informed officers that Fein instructed him to call his aunt

on a non-recorded line in order to ask her to remove a gray box from the residence. Subsequently,

the FBI executed a search warrant at the residence and discovered the gray box, containing various

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components for the construction of improvised explosive devices. The FBI also seized Fein’s

desktop computer which had been encrypted.

Procedural History. In May 2019, Fein was charged with two counts of making false

statements to the FBI, in violation of 18 U.S.C. § 1001(a)(2). Fein moved to suppress the

statements. He argued that his Miranda waiver on April 19, 2019, was not knowing and voluntary

due to his mental impairments. He also argued that he was not given a Miranda warning before

the May 3, 2019, interview at his home.

During the suppression hearing, Detective Schmitz testified that he read Fein his Miranda

rights on April 19, 2019, and Fein responded that he understood his rights and was willing to talk

to them. Schmitz also stated that he was aware of Fein’s mental health history but he appeared

rational and coherent. In addition, Schmitz noted that he did not attempt to trick or coerce Fein

during the interview. Schmitz knew that Fein had been shooting a gun at a shooting range. When

he asked Fein if he had been to any gun shops, Fein initially responded that he had not and then

denied having touched any guns.

Schmitz also testified as to the events of May 3, 2019, when he went to Fein’s home to

execute an arrest warrant. Fein was not aware that there were other law enforcement personnel

outside his home or that they had a warrant for his arrest. During questioning, no one touched

Fein, brandished or unholstered a weapon, displayed handcuffs, or blocked the door.

When Schmitz asked Fein if he had any guns or gun parts in the house, Fein lied and said

he did not. When Schmitz told Fein that lying to him would be a crime, Fein said “I want to talk

to my lawyer,” and terminated the interview. But a subsequent search, pursuant to a warrant,

revealed AR-15 kits, the vise from Home Depot, electronic components to assemble a remote-

-3- Case No. 20-1224, United States v. Fein

control detonator, and a checklist used by the Boston Marathon bombers to make a pressure-cooker

bomb.

The district court denied Fein’s motion to suppress as to both statements. It concluded that

Fein knowingly, intelligently, and voluntarily waived his Miranda rights on April 19, 2019. In

regard to the May 3, 2019 interview, the court determined that no Miranda warning was required

because Fein was not in custody when he made the false statement. Shortly after, Fein entered a

conditional plea to Count 1 of the indictment.

Prior to sentencing, the probation office prepared a presentence report (“PSR”). Fein’s

PSR calculated a base offense level of six but recommended a four-level enhancement under

USSG § 2B1.1(b)(9)(C) for fraud in violation of a prior judicial order. The PSR also applied a

four-level enhancement for possession of a dangerous weapon in connection with the offense,

pursuant to USSG § 2B1.1(b)(16)(B), and a two-level enhancement for obstruction of justice under

USSG § 3C1.1. A three-level reduction for acceptance of responsibility brought Fein’s offense

level to thirteen.

During sentencing, the district court addressed Fein’s objections to the PSR. First, the

district court overruled Fein’s objection to the application of the four-level enhancement under

USSG § 2B1.1(b)(9)(C) for violation of a prior judicial order. The court agreed that most of the

case law addressing the enhancement arose in the context of financial crimes but noted that Black’s

Law Dictionary definition of fraud includes “knowing concealment of a material fact.” The court

concluded that Fein’s fraudulent statements to the FBI officers were meant to conceal his

possession of firearms, in violation of the Kent County Probate Court’s order. Also, the court

sustained Fein’s objection to the four-level enhancement pursuant to USSG § 2B1.1(b)(16)(B) for

possession of a dangerous weapon and reduced his recommended offense level by four.

-4- Case No.

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