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Name: People v. Bradford
Case #: A116899
Court: CA Court of Appeal
District 1 DCA
Division: 1
Opinion Date: 12/29/2008

A defendant’s statement to police during an interrogation is inadmissible in the prosecution’s case-in-chief unless all four of the Miranda warnings were given prior to the interrogation, regardless of defendant’s understanding of his rights. Following appellant’s arrest for the shooting death of the victim, at the beginning of the police interrogation, the police delivered an incomplete Miranda advisement (Miranda v. Arizona (1966) 384 U.S. 436), failing to advise appellant that anything he said could and would be used against him in court. Declining to relax the requirements of Miranda by applying a totality of the circumstances test as to a defendant’s understanding of his rights, the court emphasized that advisement of each of the four warnings is an “absolute” prerequisite to the admission in court of the suspect’s statements to the police. (Miranda, supra, 384 U.S. at 468, 471, 476.) Here, prejudice under a Chapman standard (Chapman v. California (1967) 386 U.S. 18, 21-22) was found and the second degree murder conviction reversed because the prosecution used appellant’s statement for the specific purpose of removing doubt about his mental state, and ample evidence supported a finding of voluntary manslaughter as opposed to the second degree murder of which appellant was convicted. Prejudice was evaluated on the basis of evidence actually presented but excluding the improperly admitted confession.