What is the current state of the law on the Miranda Rule?

The rule prohibits continued questioning after an individual has once asserted his constitutional rights. 'After the initial assertion of the privilege, the defendant is entitled to be free of police-initiated attempts to interrogate him. Any statement made by a defendant in response to such questioning cannot be characterized as voluntary.' (People v. Randall (1970) 1 Cal.3d 948, 958, 83 Cal.Rptr. 658, 664, 464 P.2d 114, 120; People v. Burton (1971) 6 Cal.2d 714, 719, 68 Cal.Rptr. 817, 441 P.2d 793; emphasis added.)

In People v. Fioritto (1968) 68 Cal.2d 714, 719, 68 Cal.Rptr. 817, 441 P.2d 625, however, the court noted it did not disapprove of the use of statements voluntarily initiated by a suspect; such statements are sanctioned by the court and expressly authorized in the Miranda opinion. In People v. Ireland (1969) 70 Cal.2d 522, 536, 75 Cal.Rptr. 188, 450 P.2d 580, 588, the court noted that 'even a defendant in custody might make statements admissible under Miranda if it were shown that such statements were the result of the defendant's own initiative and did not arise in a context of custodial interrogation.'