What is the standard of review for a motion to suppress a statement under Miranda?

The standards of review for Miranda and voluntariness challenges are similar: For the former: "[W]e review independently a trial court's ruling on a motion to suppress a statement under Miranda. [Citation.] In doing so, however, 'we accept the trial court's resolution of disputed facts and inferences, and its evaluations of credibility, if supported by substantial evidence.' [Citation.]" (People v. Guerra (2006) 37 Cal.4th 1067, 1092-1093.) For the latter: "We review independently a trial court's determinations as to whether coercive police activity was present and whether the statement was voluntary. [Citation.] We review the trial court's findings as to the circumstances surrounding the confession, including the characteristics of the accused and the details of the interrogation, for substantial evidence. [Citation.] '[T]o the extent the facts conflict, we accept the version favorable to the People if supported by substantial evidence.' [Citation.]" (Id. at p. 1093.)

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