California, United States of America
The following excerpt is from People v. Leon, 257 Cal.Rptr.3d 592, 456 P.3d 416, 8 Cal.5th 831 (Cal. 2020):
controlling precedent and are factually distinguishable. In Cooper v. Griffin (5th Cir. 1972) 455 F.2d 1142, 1144-1145, the defendants were only 15 and 16 years old and demonstrated considerable intellectual deficiency. They read at or below third grade level and had IQs ranging between 61 and 67, well into the "mentally retarded" range. ( Id . at p. 1145.) Moreover, uncontroverted testimony from four of their special education teachers established that neither was capable of understanding the Miranda
[8 Cal.5th 845]
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