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4th District Court of Appeal, Division One
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People v. Zapata — Confession to Undercover ‘Perkins’ Operatives Inadmissible When Suspect Had Invoked Right to Counsel

Fourth District reverses a second-degree-murder conviction, holding that statements obtained from a defendant during an undercover Perkins operation were inadmissible under Miranda because the suspect had invoked his right to counsel and a known law-enforcement officer continued to ‘stimulate&

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