United States v. Davis — Fourth Circuit upheld denial of motion to suppress confession and affirmed convictions

Case
United States of America v. Tres Avery Davis
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
G. Steven Agee (George W. Bush, 2008); Stephanie D. Thacker (Barack Obama, 2012); Julius N. Richardson (Donald Trump, 2018)
Date Decided
August 19, 2026
Docket No.
25-4112
Topics
Criminal Law; Confessions; Suppression; Voluntariness
Source
Read the full opinion

Background

Tres Avery Davis pleaded guilty to distributing 40 grams or more of a mixture or substance containing a detectable amount of fentanyl, in violation of 21 U.S.C. § 841(a)(1).

Davis’s written plea agreement preserved his right to appeal the district court’s denial of his motion to suppress his confession. He argued that his statements were involuntary because questioning officers promised him leniency in exchange for information.

The Court’s Holding

The Fourth Circuit affirmed. After reviewing the record and the parties’ briefs, the court found no reversible error in the district court’s denial of Davis’s suppression motion.

The court therefore affirmed both the denial of the motion to suppress and Davis’s resulting convictions. The unpublished per curiam opinion did not provide additional analysis of the voluntariness issue.

Key Takeaways

  • Davis preserved his suppression challenge through his written plea agreement.
  • The Fourth Circuit rejected his claim that officers’ alleged promises of leniency rendered his confession involuntary.
  • The court affirmed without oral argument and designated its per curiam opinion as unpublished and nonprecedential.

Why It Matters

The decision leaves Davis’s convictions intact and confirms the district court’s refusal to suppress his confession. Because the opinion offers no detailed reasoning and is unpublished, its value as guidance for future disputes over promises of leniency and voluntariness is limited.

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