What is the scope of review for a claim that a statement was inadmissible at trial because it was obtained in violation of the Miranda rights?

California, United States of America


The following excerpt is from The People v. Ellis, E048657, No. RIF145875 (Cal. App. 2011):

When considering a claim that a statement was inadmissible at trial because it was obtained in violation of the Miranda rights, the scope of review is well established. "'We must accept the trial court's resolution of disputed facts and inferences, and its evaluations of credibility, if they are substantially supported. [Citations.]'" (People v. Bradford (1997) 14 Cal.4th 1005, 1033.) "'"[W]hen two or more inferences can reasonably be deduced from the facts," either deduction will be supported by substantial evidence, and "a reviewing court is without power to substitute its deductions for those of the trial court." [Citation.]' [Citation.]" (In re Eric J. (1979) 25 Cal.3d 522, 527.) The reviewing court then independently determines whether the challenged statement was obtained in violation of Miranda. (People v. Farnam (2002) 28 Cal.4th 107, 178.)

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