People v. Logan, 2024 IL 129054

Jessica Logan was convicted of first degree murder for asphyxiating her 19-month-old son, J.C., and sentenced to 33 years in prison in Macon County, Illinois.
Prior to trial, Logan participated in a police- and DCFS-directed video reenactment of discovering J.C.’s body; she later sought to suppress the video for lack of Miranda warnings, arguing it was a custodial interrogation.
The trial court denied the motion to suppress, finding the reenactment was not custodial, and the video was admitted at trial; Logan was later convicted, and her posttrial motion was denied.
On appeal, Logan argued the video should have been suppressed for Miranda and constitutional violations, as well as raising claims of ineffective assistance of counsel.
The appellate court affirmed her conviction, holding the encounter was not custodial and thus did not require Miranda warnings.
The Supreme Court of Illinois affirmed the conviction, but found Miranda was violated, though the error was harmless due to overwhelming evidence of guilt.

Issue	Logan’s Argument	State’s Argument	Held
Miranda Violation with Video	She was in custody for purposes of Miranda during the reenactment and should have been given warnings.	She was not in custody—the reenactment was non-custodial and voluntary.	The encounter was custodial and Miranda warnings were required, but the error was harmless.
Ineffective Assistance	Counsel failed to raise Fifth & Fourth Amendment claims re: involuntariness & illegal seizure, & failed to redact prejudicial evidence.	Any shortcomings immaterial—evidence was overwhelming; no prejudice.	No prejudice from any alleged deficiencies—evidence of guilt was overwhelming.
Plain Error	The Miranda violation was sufficiently serious to amount to plain error, requiring reversal.	Not plain error; error (if any) was harmless given the weight of evidence.	No plain error—evidence was not closely balanced, and error was not structural.

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (established the requirement for Miranda warnings during custodial interrogations)
People v. Winsett, 153 Ill. 2d 335 (Ill. 1992) (Miranda warnings are prophylactic, not constitutional rights themselves)
People v. Braggs, 209 Ill. 2d 492 (Ill. 2003) (test for custodial interrogation under Miranda)
People v. Slater, 228 Ill. 2d 137 (Ill. 2008) (factors for determining custody and voluntariness in interrogations)
In re D.L.H., 2015 IL 117341 (Ill. 2015) (objective test for custody under Miranda)