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Name: People v. Jenkins
Case #: A099675
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 09/30/2004
Subsequent History: 12/22/04: rev. den.

While the court erred in failing to suppress statements made during an unlawful detention, the admission of those statements was not prejudicial. The defendant, a suspect in a murder and an attempted murder, was arrested without a warrant for driving without a license, and was detained for over sixteen hours while officers questioned him. He was not brought before a magistrate and the officers were not engaged in necessary administrative functions related to the traffic offense; instead, the officers detained defendant in order to question him regarding the homicide investigation. The Court of Appeal concluded that while the statements made during this detention were voluntary under the Fifth Amendment, they were the product of an illegal detention and should have been suppressed. A subsequent statement made after the defendant had been out of custody for three days, however, was sufficiently attenuated from the first statements to dissipate the taint of the illegal detention. Because the second statement was admissible, the error regarding the initial statement was not prejudicial.