P. v. Washington
A gang expert opined that defendant was a member of a rival gang — the 12th Street Mafia — based on multiple items of evidence, including defendant’s statements to various booking officers. Thus, a jury found defendant guilty of the crime of active gang participation (Pen. Code, § 186.22, subd. (a)); it also found several gang enhancements true (id., subd. (b)).
Defendant contends that his statements at booking were not admissible under the routine booking question exception to Miranda v. Arizona (1966) 384 U.S. 436. We disagree. Moreover, we will hold that the asserted error was harmless beyond a reasonable doubt, because there was massive evidence, in addition to his statements, that he was a member of 12th Street.
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