Failure to Prove a Suspect Understood His Miranda Warnings
In People v. Calhoun, 382 Ill. App. 3d 1140, 1145, 889 N.E.2d 795, 321 Ill. Dec. 530 (2008), the trial court found that the State had failed to prove that the defendant affirmatively acknowledged that he understood his Miranda warnings.
During the hearing on the motion to suppress the defendant's statements, the trial court heard the testimony of the detectives who interviewed the defendant, and it indicated that it also viewed the DVD recording of the defendant's interview sometime before the hearing.
On review, the appellate court viewed the same DVD as the trial court and applied a deferential standard of review to determine whether the trial court's finding that there was no indication that the defendant understood his Miranda warnings was against the manifest weight of the evidence. Calhoun, 382 Ill. App. 3d at 1145.