Does a prison officer have to issue a Miranda warning to an inmate to coerce him into participating in an interrogation?

California, United States of America


The following excerpt is from People v. Fradiue, 80 Cal.App.4th 15, 95 Cal.Rptr.2d 1 (Cal. App. 2000):

"To determine whether prison officials have applied an additional restraint, further restricting an inmate's freedom and triggering Miranda warnings, courts must consider the totality of the circumstances surrounding the alleged interrogation." (Garcia v. Singletary, supra, 13 F.3d at p. 1492.) In our view, under the totality of the circumstances presented, no restraints were placed upon defendant to coerce him into participating in the interrogation over and above those normally associated with his inmate status. Hence, Miranda warnings were not required, and the trial court correctly rejected defendant's motion to suppress his confession.

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