Repository Collection 03
United States v. Mashburn
CASE ENTRY
Last Revised • July 9, 2026
This Source Verification Page documents the Fourth Circuit's decision in United States v. Mashburn, cited in Claim I of the Supplemental Motion. The opinion discusses the constitutional limits on deliberate "question first, warn later" interrogation strategies and explains when post-Miranda statements may be excluded if law enforcement officers intentionally delay administering Miranda warnings.
Related SMAR Citation
“[U.S. v. Mashburn, Ct. of App. 4th Cir. 406 F.3d 303 (2005)]”
Case Name
United States v. Mashburn
Date
April 25, 2005
Verification Source
United States v. Mashburn, 406 F.3d 303 (4th Cir. 2005)
Source Location
United States Court of Appeals for the Fourth Circuit
Highlighted Pages
5 - 6
Referenced in the Supplemental Motion
Page 41, Paragraph: 80
✔ Original Court Order obtained and reviewed.
✔ Relevant passages highlighted.
✔ Publicly available source
✔ Included within the Source Verification Archive
May's reliance upon United States v. Mashburn, 406 F.3d 303 (4th Cir. 2005), for the legal
principle that when law enforcement deliberately employs a "question-first, warn-later"
interrogation strategy, post-warning statements may be inadmissible unless curative measures are
taken before the subsequent questioning. Mashburn is cited to establish the Fourth Circuit's
application of the rule governing two-step interrogations and the circumstances under which postMiranda statements must be excluded. May relies upon this authority to support his claim that
APD officers questioned him while in custody prior to administering Miranda warnings and that no
curative measures were taken before Detective Romick obtained his subsequent statements.
Source Status
Cited to Support
Supporting Documents
Original Article
Link to the original article.
Highlighted Research Copy
Working research copy containing the highlighted passages cited in the Supplemental Motion.
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