People v. Riddle

In People v. Riddle (1978) 83 Cal.App.3d 563, the pregnant wife of a Los Angeles attorney had disappeared from her home under suspicious circumstances. Defendant therein was almost immediately identified as a suspect, was taken into custody and given Miranda warnings; when asked repeatedly where the victim was, defendant was silent at first but renewed interrogation, conducted over a period of several days, finally produced some incriminating information about where the body of the victim could be found. The Riddle opinion analyzed the "rescue doctrine" in the context of Miranda, noting that " the most pressing emergency of all is rescue of human life when time is of the essence." ( Riddle, supra, 83 Cal.App.3d 563, 572.) The Riddle court further declared that "we deduce that an emergency sufficient to excuse the Miranda requirements contains the following elements: Para. 1. Urgency of need in that no other course of action promises relief. Para. 2. The possibility of saving human life by rescuing a person whose life is in danger; para. 3. Rescue as the primary purpose and motive of the interrogators." ( Id. at p. 576.) The holding of Riddle was that the situation confronting the interrogating officers constituted such an emergency, and justified the renewed interrogations of the defendant.