People v. Keo
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The Court of Appeal affirmed defendant's conviction for second degree murder of his girlfriend. On appeal, defendant argued that the trial court erred in admitting statements he made while in custody to a social worker performing an investigation in a dependency proceeding filed with respect to his two sons.
The court held that the dependency investigator was not required to provide a Miranda warning before interviewing defendant; admission of defendant's statements to the dependency investigator did not violate his Sixth Amendment right to counsel; and neither Welfare and Institutions Code section 355.1, subdivision (f), nor defendant's right to due process barred the admission of defendant's out-of-court statements to the dependency investigator.
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