United States v. Robert Hulse

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 2, 2024
Docket23-1033
StatusUnpublished

This text of United States v. Robert Hulse (United States v. Robert Hulse) 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. Robert Hulse, (6th Cir. 2024).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 24a0196n.06

No. 23-1033 FILED UNITED STATES COURT OF APPEALS May 02, 2024 FOR THE SIXTH CIRCUIT KELLY L. STEPHENS, Clerk

) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE UNITED ) STATES DISTRICT COURT FOR v. ) THE WESTERN DISTRICT OF ) MICHIGAN ROBERT HULSE, ) ) OPINION Defendant-Appellant. )

Before: MOORE, NALBANDIAN, and BLOOMEKATZ, Circuit Judges.

BLOOMEKATZ, Circuit Judge. A jury convicted Robert Hulse of receiving, possessing,

and distributing child pornography based, in large part, on an illicit cache that investigators

discovered inside his house. Hulse now argues that his convictions are tainted for two reasons.

First, the district court did not suppress a recorded conversation that he had with law enforcement

personnel. Second, the district court did not dismiss the case after his internet router—which he

says would have aided in his defense—went missing. Yet the small portion of the recorded

interview that the government used at Hulse’s trial did not unlawfully incriminate him. And we

will not disturb the district court’s finding that the government didn’t take Hulse’s internet router

or the court’s conclusion that the router didn’t have any exculpatory value given that Hulse had

child pornography stored on multiple devices. We affirm. No. 23-1033, United States v. Hulse

FACTUAL BACKGROUND

Three times between October 2016 and January 2017, an undercover federal law

enforcement agent used peer-to-peer software to download files containing child pornography

from an IP address that he traced to Portage, Michigan. The resulting investigation led to the Wi-Fi

network that transmitted the child pornography, and the signal was coming from Hulse’s residence.

Based on this information, law enforcement agents obtained a search warrant for Hulse’s house

and planned to execute it on June 28, 2017.

That morning, a federal agent arrived at Hulse’s house shortly after 5 a.m. and followed

Hulse as he drove to work. When the agent and his team returned to the house to serve the warrant,

nobody answered the door. Rather than force their way into Hulse’s home, two federal agents and

a Portage Police Department officer went back to Hulse’s workplace to ask him to open the house

for them. The two federal agents went into Hulse’s office in plainclothes, identified themselves

as law enforcement, and privately asked Hulse if he would open his house after producing a copy

of the search warrant. Hulse asked the agents if he had to open the house for them, and they

responded that he did not have to, but they would force entry if he declined. The agents also

informed Hulse they wanted to speak with him about their investigation. Hulse agreed to go back

to his house with the two federal agents.

One of the agents asked Hulse if he could ride back to the house in Hulse’s car. The agent

wanted to search Hulse’s car before he got in as a safety precaution, knowing that Hulse had a

handgun registered to him. But Hulse refused to allow a warrantless search of his vehicle because

he didn’t want his colleagues to see that happening in the parking lot. Hulse did, however, allow

the agent to hold onto his work and personal cell phones and later consented to a search of the

2 No. 23-1033, United States v. Hulse

devices. The agent then rode back to Hulse’s house with him; the two made small talk along the

way.

Upon arriving at the residence, federal agents and Portage police officers entered the house

using the garage door opener and security code Hulse gave them. Hulse went inside with the agent

who rode with him. Hulse, the agent, and a Portage police detective sat down at his kitchen table

while seven more law enforcement personnel searched the house. The agent told Hulse that he

was not under arrest and free to leave, but he could not come back into the house until the search

concluded if he chose to depart. Hulse remained at the kitchen table and spoke to the agent and

the detective in a “conversational” tone. Suppression Hr’g Tr., R. 63, PageID 508. The Portage

detective recorded the ensuing conversation, which lasted 95 minutes.

The first few minutes of the recorded conversation were unremarkable, covering topics

such as his residential history and internet service provider. Then, the agent and the detective

questioned Hulse about his involvement with child pornography for about an hour and a half.

During that time, Hulse consistently denied any wrongdoing, even as the detective detailed

potentially embarrassing next steps in their investigation that Hulse might avoid with a confession.

Hulse also said that he “need[ed] the advice of an attorney” twice. Appellant’s Br. at 15–16

(reciting excerpt ending at 54:18); id. at 17–18 (reciting excerpt ending at 1:20:11). The

conversation ended shortly after Hulse said “I definitely need to be represented by an attorney”

and went to his back patio. Id. at 19 (reciting excerpt ending at 1:31:21); Suppression Hr’g Tr.,

R. 63, PageID 555–57.

Agents found child pornography on a thumb drive in Hulse’s computer room and on hard

drives in his garage. In total, investigators recovered at least 1,000 images and 100 videos

containing child pornography from the devices in Hulse’s house.

3 No. 23-1033, United States v. Hulse

PROCEDURAL HISTORY

The controlling indictment advanced a total of five counts against Hulse for his receipt,

attempted receipt, possession, and distribution of child pornography between August 16, 2010 and

June 28, 2017. In the leadup to trial, Hulse moved to suppress the 95-minute recording that the

Portage detective made during the execution of the search warrant. He also moved to dismiss the

indictment on the grounds that the government failed to preserve potentially exculpatory

evidence—his internet router—that was subject to the search warrant. The district court held a

hearing and issued a written order explaining its decision to deny both of Hulse’s motions.

Though the government had the district court’s permission to use the entire 95-minute

recording, it played only the first three and a half minutes at Hulse’s trial. The admitted excerpt

revealed that Hulse had lived by himself since he bought the house in 2009 and had always

maintained the same internet service there. He also told the agent and the detective the name of

his wireless network and said it was password protected. The admitted excerpt lacked any mention

of child pornography or other illegal activity.

The jury convicted Hulse on all five charged counts. The district court sentenced Hulse to

180 months in prison for each count, to be served concurrently with each other. Hulse timely

appealed.

ANALYSIS

I. Hulse’s Suppression Motion

In examining the district court’s decision on Hulse’s motion to suppress, we review

findings of fact for clear error and conclusions of law de novo. United States v. Henry, 429 F.3d

603, 607–08 (6th Cir. 2005).

4 No. 23-1033, United States v. Hulse

A. The Due Process Claim

Hulse argues that his statements in the recorded conversation should have been suppressed

under the Fourteenth Amendment’s Due Process Clause because they were the result of police

coercion. Under our precedent, “a confession [is] involuntary due to police coercion where”:

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