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Justia Opinion Summary
The Fourth Circuit affirmed the district court's determination that defendant violated the conditions of his supervised release and sentence of twenty months in prison. The court held that because supervised release revocation proceedings are not criminal proceedings, the introduction of unwarned admissions made by defendant to his probation officer did not violate his rights under the Self-Incrimination Clause of the Fifth Amendment. Furthermore, because the proceedings were not criminal, the government was not required to present evidence corroborating defendant's admissions.
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Primary Holding
Because supervised release revocation proceedings are not criminal proceedings, the introduction of unwarned admissions made by defendant to his probation officer did not violate his rights under the Self-Incrimination Clause of the Fifth Amendment.
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