May 27, 2026
Court of Appeal, Fourth Appellate District, Division One
The Rule of People v. Ramadhan is that statements made by a defendant to an undercover agent in a Perkins operation are admissible even after the defendant invokes the right to counsel, under circumstances where the known law enforcement officer does not participate in or stimulate the conversation after the defendant's invocation of Miranda rights.
February 2, 2026
Court of Appeal, Second Appellate District, Division One
The Rule of People v. Heaps is that ex parte communications with a deliberating jury concerning a juror's ability to deliberate require reversal unless the prosecution proves harmless error beyond a reasonable doubt, under circumstances where the trial court fails to notify counsel of the jury's note raising competency concerns and the record does not establish how the jury resolved those concerns.