California, United States of America
The following excerpt is from People v. Hernandez, F074763 (Cal. App. 2019):
The claim also fails on the merits. Although not cited in defendant's briefs, we note People v. Givans (1985) 166 Cal.App.3d 793 recognizes the possibility of Doyle error occurring under circumstances where a "Miranda warning actually is given by a private security guard who has no duty to give such a warning." (Id. at p. 796.) However, there is no evidence to suggest defendant's conversation with the security guard was preceded by an advisement of his right to remain silent.
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