People v. Chavez

Defendant was found guilty of first-degree murder on a theory of felony murder predicated on armed robbery. On appeal, defendant argued that his custodial statements should have been suppressed because investigating officers failed to read him the simplified version of the Miranda warnings required for minors, this his statement was the fruit of a warrantless arrest, that the trial court erred in excluding posts that the victim had made to social media before the shooting, and that the trial court improperly considered the proceeds from the armed robbery as “compensation" during sentencing. The appellate court affirmed, finding that while officers were required to give defendant the simplified version of Miranda for minors, the overall circumstances of the interrogation and tactics used by the officers did not violate defendant’s Miranda rights or render his confession involuntary. The appellate court also found no error with regard to the entry of evidence and that the trial court considered the proper factors during sentencing. (McBRIDE and HOWSE, concurring)