Telling defendant to put his hands against the wall and assume the position for a patdown was a seizure, and here it was without probable cause. It was not consensual. Dozier v. United States, 2019 D.C. App. LEXIS 495 (Dec. 5, 2019).
When an individual is interrogated in violation of Miranda, and the response to the questioning is itself a criminal act such as providing a false identity, Miranda’s exclusionary rule will not bar admission of the statement at a subsequent trial involving charges based on the criminal act. People v. Compos, 2019 COA 177, 2019 Colo. App. LEXIS 1841 (Dec. 5, 2019).*