People v. Saldana
19 Cal. App. 5th 432
| Cal. Ct. App. 5th | 2018Background
- Defendant Manuel Saldana, a 58‑year‑old legal immigrant with no significant criminal history, was accused by three young girls who lived in his trailer park of multiple instances of sexual touching; the allegations arose after the girls watched telenovelas and acted out scenes.
- Police forensic interviews of the children were conducted; detectives then asked Saldana to come to the station. He voluntarily went and was questioned in Spanish in a closed interview room; no Miranda warnings were given.
- Over ~40 minutes Detective Gonzales used persistent, accusatory, minimization and false‑evidence techniques, repeatedly rejecting Saldana’s denials; Saldana ultimately confessed on video and wrote an apology; he was arrested minutes later about a block from the station.
- At trial the video confession was played (with English translation) and Saldana testified he confessed because he felt he could not leave unless he admitted it; the jury convicted on four counts of lewd acts (Pen. Code § 288(a)) and the court sentenced him to six years.
- On appeal Saldana argued the interrogation was custodial and the confession should have been excluded under Miranda; the trial court had denied his pretrial Miranda motion, finding the interview noncustodial.
- The Court of Appeal reversed, holding the interrogation had become custodial before the confession and its admission was not harmless.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Saldana) | Held |
|---|---|---|---|
| Whether Miranda warnings were required because interrogation was custodial | Interview was voluntary: Saldana came to station, was told he could leave, not handcuffed, one officer, short duration — not custody | Persistent, accusatory interrogation in closed room created police‑dominated atmosphere; reasonable person would not feel free to leave | Custodial — Miranda required; confession inadmissible |
| Whether the trial court erred in admitting the confession | Admission proper because warnings unnecessary; statement voluntary | Admission violated Miranda and should be suppressed | Error to admit confession; reversal required |
| Whether any Miranda error was harmless beyond a reasonable doubt | The evidence (children’s testimony, interviews) supported conviction independent of confession | Confession was highly prejudicial, decisive, and jury replayed video during close deliberations | Not harmless; confession likely decisive; reversal warranted |
| Whether other asserted trial errors (juror misconduct, new‑trial claims) require relief | N/A (AG did not prevail on Miranda) | Preserved but unnecessary to resolve because confession reversal dispositive | Court did not reach other claims (unnecessary after reversal) |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (warning requirement when custodial interrogation is initiated)
- Howes v. Fields, 565 U.S. 499 (custody is an objective inquiry whether a reasonable person would feel free to leave)
- Stansbury v. California, 511 U.S. 318 (custody is determined from objective circumstances)
- Moore v. People, 51 Cal.4th 386 (voluntary stationhouse interview not custodial where questioning not intense or accusatory)
- Elias V. v. Superior Court, 237 Cal.App.4th 568 (discussing interrogation tactics that induce false confessions)
- Aguilera v. Superior Court, 51 Cal.App.4th 1151 (factors for custody analysis; appellate review standard)
- Corley v. United States, 556 U.S. 303 (concern about false confessions from custodial interrogation)
- Arizona v. Fulminante, 499 U.S. 279 (a confession is highly probative and its involuntary admission can be prejudicial)