May 27, 2026
Court of Appeal, Fourth Appellate District, Division One
The Rule of People v. Ramadhan is that statements made by a defendant to an undercover agent in a Perkins operation are admissible even after the defendant invokes the right to counsel, under circumstances where the known law enforcement officer does not participate in or stimulate the conversation after the defendant's invocation of Miranda rights.
March 23, 2026
Court of Appeal, Second Appellate District, Division Seven
The Rule of People v. Tzul is that a defendant's handwritten note found at a crime scene stating he found victims "having sex" and that this "fills me with rage" is admissible as circumstantial evidence of the defendant's state of mind for provocation defense, under circumstances where the statement about what defendant observed is not hearsay when offered to show defendant's belief rather than truth of the observation, and the statement about defendant's emotional reaction is admissible hearsay under Evidence Code section 1250's state-of-mind exception.