Can a defendant challenge the voluntariness of his confession under the Miranda Rule?

At trial, defendant failed to challenge Little's actions in relation to the voluntariness of his confession. He cannot do so now. (See People v. Mayfield, supra, 5 Cal.4th at p. 172.)

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Moreover, we reject any suggestion defendant's statements should have been excluded because Little failed to give defendant a Miranda advisement. As the United States Supreme Court has made clear, "the special procedural safeguards outlined in Miranda are required not [when] a suspect is simply taken into custody, but rather [when] a suspect in custody is subjected to interrogation." (Rhode Island v. Innis (1980) 446 U.S. 291, 300.) "[T]he term 'interrogation' under Miranda refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect." (Id. at p. 301, fn. omitted.)