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Name: People v. Bridgeford
Case #: F068226
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 10/27/2015

Trial court should have granted defendant’s motion to suppress his confession because police did not wait 14 days to reinterrogate him after he invoked his right to counsel. Police detained and questioned Bridgeford because they suspected he was involved in a murder. While in custody, Bridgeford invoked his right to counsel. Questioning ceased and he was released. A few hours later, police arrested Bridgeford and began to question him again. Bridgeford confessed. At trial, he moved to suppress his confession. The trial court denied that motion, relying upon People v. Storm (2002) 28 Cal.4th 1007. The jury convicted him of two first degree murders. He appealed. Held: Reversed. Under Edwards v. Arizona (1981) 451 U.S. 477, if a suspect subject to custodial interrogation invokes his right to counsel all questioning must cease until a lawyer is present unless the suspect initiates communication with police or there is a sufficient break in custody. In People v. Storm, the California Supreme Court held that a break in custody is sufficient if it gives the defendant a reasonable opportunity to consult with counsel. But in Maryland v. Shatzer (2010) 559 U.S. 98, the U.S. Supreme Court clarified that, to be sufficient, a break in custody must be at least 14 days. Here, the break in custody lasted only a few hours. Accordingly, under Edwards and Shatzer, Bridgeford’s confession during the second interrogation should have been suppressed. Its erroneous admission was prejudicial under Chapman because “A confession is like no other evidence” (Arizona v. Fulminate (1991) 499 U.S. 279, 296) and the other evidence admitted in the case was weak and contradicted.