New York Court of Appeals
The People of the State of New York v. Elias Barrientos Sirno
November 27, 199076 N.Y.2d 967
Summary
The New York Court of Appeals affirmed the Appellate Division, holding that the defendant's conduct after being given Miranda warnings—reading a Spanish version and writing "yes" to each warning—constituted an implied waiver of his Miranda rights, rendering his statement admissible. The Court relied on prior New York and federal precedent that a waiver may be inferred from a suspect's clear understanding of the warnings and cooperative conduct. Justice Titone dissented, arguing that the waiver was not supported by any affirmative acknowledgment and should be deemed ineffective.