People v. Logan

This case presents question as to whether trial court properly denied defendant’s motion to suppress statements she made during video-recorded reenactment of scene, where her 19-month old son had died. Prior to reenactment, defendant was told by DCFS investigator that defendant needed to participate in reenactment as part of criminal investigation, and defendant made her statements during reenactment without having received any Miranda warnings. Defendant was eventually charged and convicted of murder of her son. Appellate Court, in affirming trial court, found that Miranda warnings were not necessary, because defendant was not in custody during reenactment, since defendant’s age, intelligence and mental makeup did not show that she was in custody during reenactment , and since reasonable person who was innocent of any crime would have believed that she could terminate encounter and leave.