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Law School Case Brief

People v. Ireland, 70 Cal. 2d 522 - 75 Cal. Rptr. 188, 450 P.2d 580 (1969)

Rule:

The teaching of Miranda does not permit a court to characterize as "voluntary" or "spontaneous" any statements specifically obtained through custodial interrogative processes undertaken subsequent to a defendant's assertion of the privilege, for those are the very processes which must cease at that moment. The cessation of custodial interrogative processes upon assertion of the privilege is one of the protective devices" which must be employed to dispel the compulsion inherent in custodial surroundings and any statement obtained without the use of that device is not admissible.

Facts:

Defendant Patrick Ireland and his wife, Ann Lucille Ireland, experienced marital difficulties, which the two attempted to fix. Their efforts were unsuccessful, and Ann soon became involved in an extramarital relationship. Ann confided with Mrs. Janice Blount, a family friend who had known defendant for some 11 years, and told the latter that she knew her husband was going to kill her, as he would not let her leave. Defendant and Ann again agreed to take steps to fix their marriage, and during the day of the incident, Ann displayed a sullen and incommunicative attitude in response to defendant’s attempts to talk to her. Moreover, defendant had been drinking. During the latter part of the day, defendant asked Ann to talk, and shortly thereafter, defendant shot and killed Ann. During the trial for the murder charge against defendant, the trial court allowed the testimony of Mrs. Janice Blount, who recalled Ann’s statement regarding defendant’s plan to kill her. Furthermore, extrajudicial statements made by the defendant while in the police car after the shooting were admitted as evidence, even after the defendant asked for his attorney after making the statements. The trial court convicted defendant of murder in the second degree. On appeal, the defendant asserted that certain of his constitutional rights were violated by admitting the testimonies presented by the prosecution.

Issue:

Was the defendant’s conviction proper, notwithstanding the fact that certain testimonies alleged to have violated defendant’s constitutional rights were admitted as evidence?

Answer:

No.

Conclusion:

The Supreme Court of California reversed defendant’s conviction, and held that the testimony offered by Mrs. Janice Blount was hearsay under Cal. Evid. Code § 1200(a). According to the court, the only purpose for its admission was to show that the matters therein stated were true. The physical fact that the words in question were spoken by Ann had no possible bearing upon the issues in the case except insofar as that fact tended to prove the truth of the matters asserted in those words. The court stated that it was clear at the outset that the declarant Ann’s state of mind on the day of her death was not itself an issue in the case; hence, the court held that the trial court committed a prejudicial error in admitting Blount’s testimony. The statement in question not only reflected Ann's state of mind at the time of utterance; it also constituted an opinion on her part as to conduct which defendant would undertake at a future time. Furthermore, the court held that all of defendant’s statements made after he asked for his attorney were erroneously admitted. According to the court, defendant’s assertion of the privilege should have operated to shut down the machinery of the custodial interrogation.

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