People v Mercado

Holding The court affirmed the conviction, holding that the defendant’s Miranda waiver was valid and not limited to the specific subject of the bench warrant arrest. Additionally, the court found no due process violation in the curtailment of questioning regarding police deception, as the officers were lawfully permitted to question the defendant on the present charges despite his right to counsel attaching to unrelated charges.

The court’s words

As a general rule, there is no 'limited' Miranda waiver.

2026 NY Slip Op 06069, at the official text

A suspect's awareness of all the possible subjects of questioning in advance of interrogation is not relevant to determining whether the suspect voluntarily, knowingly, and intelligently waived his Fifth Amendment privilege

2026 NY Slip Op 06069, at the official text

a defendant may be 'lawfully questioned on the present charges when he [is] returned on a bench warrant'

2026 NY Slip Op 06069, at the official text