State v. Hanson
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The Supreme Court affirmed the decision of the court of appeals affirming the circuit court's denial of Appellant's postconviction motion, holding that, as a matter of first impression, Miranda warnings are not required at John Doe proceedings.
Appellant was convicted of murder and sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed, holding (1) Appellant's Sixth Amendment right to confrontation was not violated because his John Doe testimony regarding the statement of his estranged wife to police was not offered to prove the truth of the matter asserted; (2) Appellant's claim that his trial counsel was ineffective for failing to object to the admission of his John Doe testimony because he was not read all of the Miranda warnings failed because the law was unsettled as to whether Miranda warnings were required at the John Doe proceedings; and (3) Miranda warnings are not required at John Doe proceedings.
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