More on Prolonged Detentions and Miranda Questions Over Statements Made to an Undercover Officer

• Questions asked during a lawful traffic stop during the normal time it takes to issue a citation do not unlawfully prolong the traffic stop. Placing an undercover police officer in a suspect’s jail cell to record the suspect’s incriminating statements is lawful. 
• Prolonged detentions during a traffic stop 
• Undercover police officer placed in a jail cell with a defendant 
• Statements made to an undercover police officer and the lack of coerciveness 

A traffic stop is not unlawfully prolonged as long as the officer diligently pursues the purpose of the stop. An officer asking questions unrelated to the purpose of the stop while also pursuing information relevant to the stop is not illegal. An undercover law enforcement officer posing as a fellow inmate need not give Miranda warnings to an incarcerated suspect before asking questions, even if that suspect had earlier invoked his right to the assistance of counsel. This is because when a jail inmate is talking to an undercover officer, there is no coerciveness involved. (But see note below.)

Defendant Jason Felix was suspected of having murdered two individuals, in Montebello (Ricardo Mota, March 27, 2017) and in San Fernando (Jorge Gonzalez-Ortega, June 15, 2017), who were suspected of dealing drugs. Felix subsequently fled ....