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Name: People v. Felix (2024) 100 Cal.App.5th 439
Case #: B317938
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 03/07/2024
Subsequent History: Opn. modified 3/12/2024
Summary

Defendant, who was a foreign national driving a car that belonged to a third party, was lawfully detained while an officer made further inquiries of the dispatcher performing the records check for defendant and the owner of the vehicle. Following a valid traffic stop in Utah, Felix provided an officer with an identification card from Mexico and vehicle registration in the name of a third party from California. He was detained approximately 12 minutes while the officer performed a records check and asked dispatch for additional information. The officer then obtained consent to search the vehicle just prior to dispatch confirming the search results for the owner of the car were inconclusive. Drugs and other contraband were discovered during the search and Felix was arrested. His motion to suppress the evidence was denied. On appeal, he argued the traffic stop was unreasonably prolonged in violation of his Fourth Amendment rights, and his subsequent consent to the warrantless search of the car was invalid as a product of his wrongful detention. Specifically, he argued the detention became illegal once the dispatcher provided a response to the records check and the officer continued to ask questions and detain him for another five to six minutes, instead of writing a citation or releasing him. Held: Affirmed. The Court of Appeal reviewed the circumstances of the traffic stop and concluded the detention was lawful. It was entirely reasonable for the officer to make further inquiries of the dispatcher regarding the registered owner of the car and it was reasonable for the officer to take a few minutes to confirm Felix’s information when a Spanish-speaking officer arrived. Thus, Felix’s consent to search was obtained during a lawful detention.

Defendant’s incriminating statements made to an undercover detective while in a holding cell, but after asserting his Miranda rights, were properly admitted at trial. After Felix invoked his Miranda rights during a police interrogation, he was placed in a holding cell with a wired undercover detective dressed as a fellow detainee. Felix initiated a conversation and made incriminating statements. The investigating officers then removed Felix from the cell, told him they had received evidence against him, and returned him to the cell. Felix continued to make incriminating statements about two murders to the undercover detective. On appeal, Felix argued his statements to the undercover detective were erroneously admitted at trial because they were obtained after he had invoked his Miranda rights. Held: Affirmed. The Court of Appeal concluded that the use of an undercover agent to elicit statements from a suspect after the invocation of Miranda rights under these circumstances did not amount to a coercive interrogation under Illinois v. Perkins (1990) 496 U.S. 292. The initial interrogation ended once Felix invoked his Miranda rights, and the incriminating statements made to the undercover officer during the subsequent conversation were not made under coercion. The fact that detectives removed defendant from the cell to advise that they had evidence against him did not amount to an additional interrogation because Felix waited until the detectives left to resume his voluntary conversation with the undercover detective. [Editor’s Notes: (1) The dissent would have found that the second interrogation was coercive within the meaning of Edwards v. Arizona (1981) 451 U.S. 477. (2) The majority did not address whether the use of the undercover detective violated due process.]

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/B317938M.PDF