People v. Logan
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The Supreme Court of the State of Illinois evaluated a case involving Jessica Logan, who was convicted of first-degree murder for the death of her 19-month-old son. Before her trial, Logan moved to suppress a video reenactment of her son’s death, arguing that police should have given her Miranda warnings. The trial court denied the motion to suppress and the video was admitted as evidence. The appellate court affirmed the trial court's judgment, finding that the reenactment was not custodial.
The Supreme Court of Illinois affirmed the judgment of the appellate court, but for different reasons. The court found that Logan was in custody during the reenactment and should have received Miranda warnings. Despite this, the court held that admitting the reenactment as evidence did not amount to plain error, as the evidence of Logan's guilt was not closely balanced. The court also rejected Logan's claims that her trial counsel rendered ineffective assistance, finding that she had not shown a reasonable probability that the outcome of the trial would have been different if her counsel had acted differently.
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