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Murder Conviction Reversed: Confession Was Prejudicial Error

People v. Sumagang Court: California Courts of Appeal, Docket: H044023 (Sixth Appellate District), Opinion Date: September 29, 2021. Police found Sumagang asleep in a car in a remote rural area. Sangco’s deceased body was lying on top of him. The police took Sumagang into custody and a detective subsequently interviewed him in two stages—first without warning him under Miranda, and then again after warning him. In both parts of the interview, he admitted choking Sangco until she stopped breathing or moving. He claimed she had asked him to kill her, and he said he had intended to kill himself as well. Sangco, who was 20 years old, suffered from depression and had previously expressed suicidal thoughts. Toxicology tests showed she had a “potentially toxic” level of drugs in her body at the time of death. The prosecution charged Sumagang with willful, deliberate, and premeditated murder (Pen. Code 187(a)). Convicted, he was sentenced to 25 years to life. The court of appeal reversed. The trial court erred by denying Sumagang’s motion to exclude the confession under Missouri v. Seibert and Sumagang was prejudiced by the admission of the confession at trial. The court concluded the detective deliberately undermined Miranda by employing the two-step interrogation tactic. There was no practical justification for treating the second stage of interrogation as distinct from the first, unearned, and inadmissible segment.


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