People v. Cetlinski

In People v. Cetlinski, 435 Mich 742, 760; 460 NW2d 534 (1990), the Supreme Court of Michigan held that the use of a defendant's prior statements, including omissions, given during contact with the police, prior to arrest or accusation, does not violate the defendant's constitutional rights, but rather is an evidentiary issue. Cetlinski did not directly address the issue whether the admission as substantive evidence of testimony concerning a defendant's silence before custodial interrogation and before the Miranda warnings have been given is a violation of the defendant's constitutional rights.