State v. Council, 232 N.C. App. 68 (Jan. 21, 2014)

No prejudicial error occurred when the trial court denied the defendant’s motion to suppress statements made by him while being transported in a camera-equipped police vehicle. After being read his Miranda rights, the defendant invoked his right to counsel. He made the statements at issue while later being transported in the vehicle. The court explained that to determine whether a defendant’s invoked right to counsel has been waived, courts must consider whether the post-invocation interrogation was police-initiated and whether the defendant knowingly and intelligently waived the right. Although the trial court did not apply the correct legal standard and failed to make the necessary factual findings, any error was harmless beyond a reasonable doubt, given that the defendant’s statements contained little relevant evidence, they were not “particularly prejudicial,” and the other evidence in the case in strong.