Anaya v. FBI – False Confession


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Agent Blackburn asked Anaya at his second interview if he would agree to undergo a polygraph exam and Anaya agreed. Although neither Agent Blackburn nor Agent Dawson explained what exactly was involved with taking such an exam, Anaya appeared unfazed by it at any point – nor was he nervous, shaky, or upset during it.

The court determined that Anaya did not hold an unreasonable belief that he could not leave during his polygraph exam and was properly advised of his rights. Magistrate Judge Duffy considered all circumstances surrounding Anaya’s statements being voluntary and determined that all were voluntary in nature.

Dr. Manlove testified that he could not determine that Anaya made his statements voluntarily to the agents. Instead, his opinion was that he falsely confessed due to believing the polygraph test was 99 percent accurate; feeling power imbalance with two white FBI agents in an apartment belonging to government and being aware that an accuser had brought allegations against him.

The court agrees with the lower court in finding Anaya’s waiver of his Miranda rights was informed and deliberate, as Agent Dawson advised him accurately of his right not to answer any questions and be free to terminate the interrogation at any time. Furthermore, Anaya understood potential consequences if he refused to waive his rights such as being charged with federal crimes carrying minimum sentences of 30 years or even life imprisonment.

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