What is the current state of the law on the interpretation of the Miranda code?

With respect to the scope of our review as to whether a Miranda violation occurred, "'We must accept the trial court's resolution of disputed facts and inferences, and its evaluations of credibility, if they are substantially supported. [Citations.] However, we must independently determine from the undisputed facts, and those properly found by the trial court, whether the challenged statement was illegally obtained.' [Citations.] We apply federal standards in reviewing defendant's claim that the challenged statements were elicited from him in violation of Miranda. [Citations.]" (People v. Bradford (1997) 14 Cal.4th 1005, 1033.)

Illinois v. Perkins (1990) 496 U.S. 292 [110 S.Ct. 2394, 110 L.Ed.2d 243] (Perkins) is instructive. In Perkins, the United States Supreme Court held that Miranda was not implicated by a conversation between an incarcerated suspect and an undercover

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