United States v. Katrina Ann Tingle

Katrina Ann Tingle appeals her conviction of conspiracy to purloin and purloining funds from a federal credit union, in violation of 18 U.S.C. §§ 371 , 657. Tingle argues that her confession, which supported the conviction, was involuntary.

I

On May 21, 1980, Tingle, 21, was an employee of the San Diego Navy Federal Credit Union. Early that morning, Tim Hurley, an employee of the credit union, arrived for work and found Tingle bound and gagged in the back room of the office. The credit union safe was open, and all the money had been removed. Tingle told Hurley that she had been attacked by an unknown assailant who had tied her up and stolen the money from the safe.

Hurley called the local police who arrived and questioned Tingle. The Federal Bureau of Investigation (FBI) was notified of the “robbery.” FBI Special Agents Sibley and Ayers arrived at the credit union, spoke to the local police officer, and escorted Tingle to their automobile parked in front of the credit union in order to speak with her privately.

Tingle sat in the back seat of the automobile with Sibley while Ayers sat in the front seat. The interrogation which followed lasted for approximately one hour. Tingle…