AZ: Presenting a consent form after def lawyers-up doesn’t violate Miranda

Defendant was Mirandized, and she lawyered up. She was presented with a consent form for her cell phone with the understanding that if she didn’t consent they’d get a search warrant. She didn’t ask for a lawyer, and she consented. This was not a violation of Miranda. State v. Sallard, 2019 Ariz. App. LEXIS 925 (Oct. 11, 2019).

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