
Miranda and the Equivocal Invocation
Robert C. Phillips
Deputy District Attorney (Ret.)
August, 2014
In a gruesome series of murders as graphically described in the California Supreme Court decision of People v. Suff,[1] and reminiscent of the television series “Criminal Minds,” twelve prostitutes disappeared off the streets of the Cities of Lake Elsinore and Riverside between June, 1989, and December, 1991. Their bodies were eventually found, one by one, abandoned in fields and other rural areas. Commonalities indicating that they had all been murdered by the same serial killer included, in addition to being prostitutes, that each victim met her end by asphyxiation due to strangulation, four of the victims had also suffered stab wounds to the chest, and the right breast of three of the victims having been excised and left near the ....