P. v. Johns
Defendant Janene Kathleen Johns challenges her conviction for gross vehicular manslaughter while intoxicated. She contends the court violated her rights under Miranda v. Arizona (1966) 384 U.S. 436 (Miranda) by admitting into evidence two sets of her incriminating statements. She further contends the court erred by barring her from examining a witness as to his possible bias.
Court affirm. Defendant was not in custody when she made her first set of incriminating statements. She impliedly waived her Miranda rights before making her second set of statements. And while the court should have allowed defendant to examine the witness as to his possible bias, the error was not prejudicial.
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