P. v. Sauceda-Contreras
Annotate this CaseAfter a jury trial, Defendant, who spoke Spanish, was convicted of first degree murder. At issue on appeal was whether, while Defendant was in custody and after a law enforcement officer read Defendant his Miranda rights, Defendant's response to whether a detective could speak to Defendant was sufficiently ambiguous to justify the officer in seeking to clarify whether Defendant was attempting to invoke his right to counsel, or whether he was desirous of waiving his Miranda rights and speaking with the detective without an attorney present. The trial court concluded that Defendant's waiver of Miranda rights was voluntary, knowing and intelligent. The court of appeals reversed. The Supreme Court reversed, holding (1) Defendant's reply to the officer's inquiry was sufficiently ambiguous to justify her seeking further clarification of his intent, consistent with the Court's holding in People v. Williams; (2) Defendant's responses made clear he was willing to speak with the detective at that time without an attorney present; and (3) therefore, under the totality of the circumstances, Defendant's waiver of Miranda rights, including his right to counsel, was voluntary, knowing, and intelligent.
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