What evidence supports a defendant's Miranda claim?

California, United States of America


The following excerpt is from People v. Valencia, APP1400147 (Cal. Super. 2015):

However, after having reviewed the record we do detect one Miranda-defective statement. At one point Officer Seel appeared to ask whether defendant "talk[ed] to somebody to tell you to do all this," and defendant responded, "[n]o sir, I've just been watching videos like a fucking idiot." The most reasonable interpretation of the officer's question is that he was inquiring into whether defendant had been advised ahead of time on how to interact with police in a DUI investigation, and defendant's reply tends to show that he did indeed prepare himself in purported methods to evade responsibility for a DUI despite being guilty of the crime. However, in light of the ambiguity in the statement, as well as the other strong, ample, and undisputed evidence against defendant, we conclude that the admission of this exchange was harmless beyond a reasonable doubt. (People v. Peracchi (2001) 86 Cal.App.4th 353, 364 ["[w]hen a statement obtained in violation of Miranda is erroneously admitted into evidence, the conviction may be affirmed if the error is harmless beyond a reasonable doubt"].) Accordingly, we reject defendant's Miranda claim.

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