I had filed a motion awhile ago to suppress a statement from my client that had been obtained in violation of his Miranda rights. We were scheduled for a hrg today on it. I thought it was basically a slam dunk given the facts of the case.
And apparently so did the prosecutor. He emailed me this morning & said he agreed that my guy was clearly in custody & the officer should have Mirandized my client before questioning him. Since that didn't happen, the prosecutor agreed to stipulate that the statement by my client couldn't be used by the state at trial.
So, I win!! Without even needing to go through the whole process of having a hrg & writing a brief, etc.
It's always a pleasant surprise when the prosecution agrees w/ my legal analysis of a case.