People v. Duff

In People v. Duff (2014) 58 Cal.4th 527, the defendant waived his rights and spoke with one officer, then asked to stop; as the officer was preparing to leave, the defendant asked to speak with a different officer. The second officer appeared 23 minutes later and, after small talk and a bathroom break, questioned the defendant and obtained his confession. (Id. at pp. 554-555.) The court noted that the second questioning was "just minutes later, in the very same location as before, by a detective specifically summoned by the defendant, a defendant the trial court found had been in prison four times before and was quite familiar with the criminal justice system." (Id. at p. 555.)