Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA v. JARVIS CLAYBORN ) ) ) ) ) ) ) ) ) )

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-07-29 The sixth-circuit affirmed the district court’s denial of Jarvis Clayborn’s motion to suppress post-Miranda statements obtained during a custodial interrogation following an initial, unwarned questioning session. The court applied the five-factor test from *Missouri v. Seibert* and Sixth Circuit precedent (*United States v. Woolridge*) to determine whether Clayborn had a “genuine choice” to remain silent after receiving midstream Miranda warnings. The court held that the statements were admissible because, although the initial questioning was complete, three hours elapsed between the two rounds of interrogation, the second round was conducted by a different officer at a new location (the police station), and the second officer did not reference or rely on the prior unwarned confession to elicit the subsequent admission. The court further clarified that under Sixth Circuit law, the admissibility of such statements is determined by an objective test focusing on the suspect’s perspective, rendering the officers’ intent or any alleged departmental policy regarding two-step interrogations irrelevant to the constitutional analysis. Consequently, Clayborn’s conviction for possession of a machinegun under 18 U.S.C. § 922(o) stands. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.