United States v. Michael Monroe James

── United States v. Michael Monroe James ── Court: Court of Appeals for the Sixth Circuit Date: May 20, 2026 Category: General NOT RECOMMENDED FOR PUBLICATION File Name: 26a0222n.06 No. 25-3552 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED May 20, 2026 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) v. UNITED STATES DISTRICT ) COURT FOR THE ) MICHAEL JAMES, NORTHERN DISTRICT OF ) OHIO Defendant-Appellant. ) ) OPINION ) ) Before: BOGGS, BATCHELDER, and MOORE, Circuit Judges. BOGGS, Circuit Judge. This appeal challenges the denial of a motion to suppress incriminating statements obtained during a police interview with then 28-year-old Michael James and evidence recovered from a search of his phone—namely, hundreds of files depicting the sexual abuse of children. James contends that his Miranda rights were violated and that the search exceeded the scope of his consent, in violation of the Fourth Amendment. The district court rejected those arguments, and rightly so. Because the record supports the court’s conclusions and reveals no constitutional violations, we affirm. I In June 2024, an undercover FBI agent posing as a minor posted on an anonymous social media application called “Whisper” that she was pregnant and feared her parents’ reaction. Michael James, using the username “Ambient_Sun,” initiated contact by sending her private messages. After asking her age and learning that she was eleven, James did not end the exchange. No. 25-3552, United States v. James Instead, he described sexual acts that he intended to perform on the child, sent a photograph of his genitalia, and stated that he would travel to meet her the next day, asking for her address and proposing to take her to a hotel for sex. The messages also contemplated repeated sexual activity, repeated impregnation, and James’s continued control over the child’s life, including statements that any daughters she might have would be subjected to similar treatment at a young age. This exchange led to two law-enforcement officers—FBI Special Agent Austin Johnston and FBI task-force officer Katherine Jarvis—paying James a visit at his Ohio residence the following month. Upon arrival, the officers were calm and cordial, reassuring James that they “just want[ed] to have a conversation” about his online activities and did not intend to arrest him that day. During the subsequent in-home interview, which lasted less than thirty minutes, James signed a consent form that advised him of his “right to refuse consent” and authorized a “complete search” of his phone and a seizure of “any items . . . related to [the]