United States v. Mullins
Split Score
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Case Summary
Disposition
Affirmed
The Tenth Circuit affirmed Tyler Jay Mullins’s federal murder convictions arising after his Oklahoma state conviction was vacated under McGirt v. Oklahoma. The court rejected challenges under the Jury Selection and Service Act, Federal Rule of Evidence 410, and Federal Rule of Criminal Procedure 16, holding Mullins’s Jury Act motions were procedurally barred, his statements leading police to the victim’s body were not protected by Rule 410, and any discovery error was harmless.
Circuit Split Identified
Legal Issue
Whether Federal Rule of Evidence 410(a)(4) bars admission of statements made to law-enforcement officers (rather than to a prosecutor) when the officers allegedly have authority to negotiate a plea.
Circuit Positions
Strict textual approach – Rule 410(a)(4) covers only statements made directly to a prosecuting attorney.
Broader approach – Rule 410(a)(4) also covers statements to law-enforcement agents who have express or implied authority to negotiate a plea.
Conflict Summary
Some circuits interpret Rule 410(a)(4) strictly, excluding only statements made to an attorney for the prosecuting authority; others extend the protection to statements made to law-enforcement agents who are expressly or impliedly authorized by a prosecutor to engage in plea discussions.