How have courts interpreted the Miranda rights of a suicidal, acutely psychotic defendant in a murder case?

California, United States of America


The following excerpt is from People v. Yang, F067353 (Cal. App. 2015):

Third, in People v. Panah (2005) 35 Cal.4th 395 (Panah), the defendant murdered an eight-year-old girl. (Id. at p. 408.) When the defendant was apprehended he had slashed wrists, appeared under the influence of drugs or alcohol, and was uttering nonsensical statements about the victim. The defendant was transported to a hospital for medical treatment and the treating physician testified he found the defendant agitated and delusional. (Id. at p. 416.) The defendant was having auditory hallucinations, acting inappropriately, and the slashes on his wrists appeared to have been self-inflicted. The treating physician concluded the defendant was suicidal, acutely psychotic, and hearing "'command hallucinations'" (ibid.) from figures telling the defendant to kill himself. The physician noted the defendant was under the influence of drugs and could not determine whether the psychosis was a result of the drugs or other factors. (Ibid.) At the hospital, a detective interviewed the defendant after advising him of his Miranda rights, which the defendant waived. (Id. at p. 470.) The trial court found the questioning at the hospital permissible under Miranda, concluding the defendant's medical and psychological condition did not render his waiver involuntary. (Id. at pp. 470-471.)

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