The California Supreme Court affirmed a judgment of conviction and penalty. The court held that a detective’s conversation, during a lengthy wait in a hospital emergency room, with an arrestee who had previously invoked his right to counsel did not constitute an interrogation.

The morning after he was placed in a jail cell with Ronnie Dement and two other inmates, Greg Andrews was found dead. The statements of Dement’s fellow cellmates implicated him in Andrews’s death. An autopsy later revealed that Andrews had been brutally beaten and kicked before being choked to death.