What is the test for a claim that a statement was obtained in violation of Miranda?

California, United States of America


The following excerpt is from People v. Maldonado, F067097 (Cal. App. 2014):

In reviewing a trial court's disposition of a claim that a statement should have been excluded because it was obtained in violation of Miranda, we accept the trial court's findings on any disputed matters of fact if supported by substantial evidence, and we review de novo the legal issue of whether the undisputed facts and the facts found by the trial court and supported by substantial evidence show that the challenged statement was legally obtained. (People v. Gonzalez (2005) 34 Cal.4th 1111, 1125.) There is no dispute here about the words of defendant upon which the alleged invocation of the right to counsel is based, or about the circumstances under which those words were spoken, so we are left only with the legal question of whether these facts show that defendant's statement was admissible.

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