United States v. Fowler: Inapplicability of the Miranda Exclusionary Rule at Sentencing Absent Intent to Enhance Penalty

Introduction

United States v. Fowler, decided by the Tenth Circuit on April 22, 2025, addresses an important sentencing question: whether statements obtained in violation of Miranda v. Arizona may be considered at sentencing, and if so, under what circumstances. Defendant Zachary Charles Fowler appealed a 624-month total sentence imposed for kidnapping, carjacking, and brandishing a firearm, arguing among other things that the district court improperly relied on statements obtained without timely Miranda warnings. The Government countered that even if those statements were technically inadmissible at trial, they could still inform the court’s sentencing decision. The panel of Judges Matheson, Phillips, and McHugh unanimously affirmed the sentence, holding that the Miranda exclusionary rule does not apply at sentencing absent evidence that law-enforcement officers sought to enhance the sentence by eliciting inadmissible statements.

Summary of the Judgment

The Tenth Circuit, reviewing for substantive reasonableness under 18 U.S.C. § 3553(a) and the abuse-of-discretion standard, rejected Fowler’s contentions. It first explained that the Miranda exclusionary rule bars admission of statements only at trial and does not extend to sentencing unless the defendant shows that officers interrogated him in violation of Miranda for the specific purpose of obtaining a harsher punishment. Relying on its Fourth Amendment exclusionary-rule precedents—particularly United States v. Ryan, 236 F.3d 1268 (10th Cir. 2001)—the court held that the same rationale governs Miranda violations: absent evidence that the officers sought to influence the sentence, a district court may consider all relevant evidence, including statements obtained illegally. The panel further held that the district court gave appropriate weight to the § 3553(a) factors, did not abuse its discretion in addressing Fowler’s youth, and did not create unwarranted sentencing disparities. It therefore affirmed the 624-month sentence.

Analysis

Precedents Cited

Miranda v. Arizona (384 U.S. 436, 1966): Established the requirement of procedural warnings before custodial interrogation to protect the Fifth Amendment right against self-incrimination.
Oregon v. Elstad (470 U.S. 298, 1985): Described the “Miranda exclusionary rule” as prohibiting admission of unwarned statements at trial.
United States v. Ryan (236 F.3d 1268, 10th Cir. 2001): Held that the Fourth Amendment exclusionary rule does not apply at sentencing unless law-enforcement officers acted to enhance a sentence by conducting an unconstitutional search or seizure.
United States v. Salazar (38 F. App’x 490, 10th Cir. 2002): Unpublished decision extending Ryan’s Fourth Amendment rationale to the Miranda exclusionary rule at sentencing.
Gall v. United States (552 U.S. 38, 2007) and United States v. Halliday (665 F.3d 1219, 10th Cir. 2011): Articulated the abuse-of-discretion standard for reviewing substantive reasonableness of sentences under § 3553(a).

Legal Reasoning

The court’s reasoning unfolds in several steps:

Sentencing Evidence vs. Trial Evidence
While Miranda bars use of unwarned custodial statements at trial, the panel emphasized that sentencing is procedurally distinct. The exclusionary rules are designed to deter unlawful law-enforcement conduct, but only where deterrence yields benefits that exceed the societal costs of excluding reliable evidence from punishment proceedings.
Extension of Ryan to Miranda Violations
In Ryan, the Tenth Circuit refused to apply the Fourth Amendment exclusionary rule at sentencing absent proof that officers sought to influence the sentence. Fowler’s panel cited Salazar to clarify that the same logic controls Miranda violations: police do not typically interrogate suspects in order to secure a higher sentence, so excluding statements from sentencing would not further deterring misconduct.
No Evidence of Intent to Enhance Sentence
Fowler identified no evidence that officers purposely delayed or omitted Miranda warnings to obtain incriminating statements for sentencing leverage. Without such proof, the district court was free to consider Fowler’s recorded admissions and denials in weighing the § 3553(a) factors.
Deference to District Court’s § 3553(a) Balancing
A within-Guidelines sentence carries a presumption of substantive reasonableness. The district court had carefully walked through Fowler’s history and characteristics, the nature of the offense, the need for deterrence, and the need to protect the public. Its consideration of Fowler’s denials and victim-blaming went to the seriousness of the crime and public protection—factors squarely within § 3553(a).
Youth and Sentencing Disparity Arguments
Fowler argued that the court overlooked his age and created an unwarranted disparity with other kidnapping cases. The panel held that a district court is not required to grant a variance for youth, and that a within-Guidelines sentence “necessarily” avoids unwarranted disparities among similarly situated offenders.

Impact

United States v. Fowler confirms and clarifies the boundaries of exclusionary-rule doctrine in sentencing:

It cements the principle that Miranda’s trial-only exclusionary rule does not automatically carry over to sentencing hearings.
It underscores that defendants must demonstrate bad-faith or sentence-enhancing intent behind law-enforcement violations before sentencing courts will exclude otherwise relevant evidence.
Sentencing courts are thus empowered to consider custodial statements—Miranda-tainted or not—so long as there is no indication the statements were procured purely to secure a harsher sentence.
This ruling is likely to discourage collateral attack arguments seeking to bar sentencing consideration of any Miranda-violative statements, absent a showing of improper motive by interrogators.

Complex Concepts Simplified

Miranda Exclusionary Rule
Normally, if police question someone in custody without giving the standard Miranda warnings (you have the right to remain silent, the right to an attorney), any statements the person makes cannot be used against them at trial. That’s the “Miranda exclusionary rule.”

Sentencing vs. Trial Exclusionary Rules
At sentencing, judges gather information to decide an appropriate punishment under federal law. The Tenth Circuit explains that the costs of excluding information at this stage are generally greater than any deterrent benefit because officers rarely interrogate with an eye toward boosting the sentence. Thus, absent proof of improper motive, even a statement that would be barred at trial can inform a judge’s sentencing decision.

Abuse-of-Discretion Standard
Appellate courts give wide latitude to trial judges in choosing sentences. They overturn only if a sentence is “arbitrary, capricious, whimsical, or manifestly unreasonable.” When a sentence falls within the Guidelines range, there is a strong presumption that it is reasonable.

Conclusion

United States v. Fowler establishes a clear, precedential rule: the Miranda exclusionary rule does not automatically preclude consideration of custodial statements at sentencing, unless a defendant demonstrates that law-enforcement officers deliberately violated Miranda in order to secure a harsher punishment. This decision harmonizes Miranda exclusion doctrine with Fourth Amendment sentencing jurisprudence under United States v. Ryan. It reaffirms that sentencing courts retain broad discretion to weigh all relevant conduct and statements—Miranda-tainted or not—so long as the inquiry satisfies the statutory factors in 18 U.S.C. § 3553(a). Fowler thus provides guidance for lower courts and practitioners on the permissible bounds of evidentiary review in federal sentencing.