Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA v. EVAN A. GALASSO ) ) ) ) ) ) ) ) ) ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO O P I N I O N

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-08-07 The sixth-circuit affirmed the district court’s denial of Evan Galasso’s motion to suppress incriminating statements made during police questioning in a vehicle at his residence and later at an FBI office. The court held that even if Galasso was in custody during the initial car interrogation without Miranda warnings, any error was harmless because Galasso conceded on appeal that the admission of those unwarned statements did not materially affect his decision to plead guilty. Regarding the subsequent questioning at the FBI office, the court applied the *Missouri v. Seibert* objective test to determine if post-warning statements were tainted by pre-warning admissions. The court found the warnings effective because there was a significant break in time and location between interrogations, different agents conducted the sessions, and the second interrogation focused on distinct topics (hands-on offenses) rather than merely repeating the first round. Finally, the court rejected Galasso’s argument that he invoked his right to counsel during the car encounter, ruling under *Davis v. United States* that his request was not unambiguous because it was inaudible on the recording and the officer did not hear it, meaning the *Edwards v. Arizona* bar was not triggered. As a result, the conviction and 180-month sentence stand. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.