In People v. Vasquez, the second district held that police questioning of the defendant in a hospital's intensive care unit did not require Miranda warnings. As Sean Brady wrote in the latest ISBA Traffic Laws and Courts newsletter, the appellate court "reversed the trial court and ruled that the proper advisement and waiver of the right to remain silent and the right to have counsel present during questioning was unnecessary in Vasquez because the defendant was not in custody at the time of the interview and the misdemeanor DUI charge did not create a sixth amendment right to counsel." Read Sean's article.