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Name: People v. Edwards
Case #: H042144
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 05/16/2017

Trial court did not err when it allowed the prosecutor to rebut an expert’s diagnosis during the sanity phase of a murder trial by using defendant’s suppressed statements. A jury found Edwards guilty of first degree murder. During the sanity phase of his case, the trial court allowed the prosecution to use Edwards’ statements, which had been suppressed because they were made after he invoked his right to counsel, to impeach the testimony of his expert witnesses. The jury found him sane at the time of the murder. On appeal he challenged the admission of his suppressed statements. Held: Affirmed. When a defendant invokes his right to have counsel present during a custodial interrogation, any statements made in response to further questioning are inadmissible. (Miranda v. Arizona (1966) 384 U.S. 436.) However, the use of voluntary statements obtained in violation of Miranda may be used to impeach the defendant’s direct or cross-examination testimony (Harris v. New York (1971) 401 U.S. 222). In James v. Illinois (1990) 493 U.S. 307, the Court rejected the expansion of Harris to the examination of third-party witnesses, finding this would not promote the truth-seeking function to the same extent as the exception set forth in Harris, and would undermine the deterrent effect of the exclusionary rule. In contrast to James, expansion of the Harris exception to allow the use of suppressed statements to cross-examine experts during the sanity phase would further the truth-seeking process with only minimal loss of probative witness testimony, and would not diminish the deterrent effect of the exclusionary rule on police misconduct. Other jurisdictions have reached the same conclusion. The trial court properly admitted the evidence in this case.

The full opinion is available on the court’s website here: