Supreme Court of Colorado

Phillip Effland v. the People of the State of Colorado

September 27, 2010240 P.3d 868

Summary

Justice Coats, dissenting, would reject the majority's conclusions that the confession was involuntary and that the defendant was in Miranda custody. He reasoned that due-process suppression requires objectively coercive or wrongful police conduct, which he found absent, and that medical limitations alone could not establish custody when the detectives did not restrain the defendant or compel cooperation.