United States v. Watson

137 F.4th 1046
CourtCourt of Appeals for the Ninth Circuit
DecidedMay 23, 2025
Docket24-1865
StatusPublished

This text of 137 F.4th 1046 (United States v. Watson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth 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. Watson, 137 F.4th 1046 (9th Cir. 2025).

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.

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Bluebook (online)
137 F.4th 1046, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-watson-ca9-2025.