Supreme Court of Colorado
The People of the State of Colorado, Plaintiff-Appellant v. Aaron Bradley Holt, Defendant, Appellee
June 21, 2010233 P.3d 1194
Summary
The court affirmed suppression of Holt's incriminating statements because he was subjected to interrogation while in Miranda custody without receiving the required warnings. Considering the totality of the circumstances, the court held that a reasonable person would have felt restrained in a manner similar to formal arrest. Justice Coats, dissenting and joined by Justice Eid, would have found no Miranda custody and criticized the majority for applying a focus-of-the-investigation approach.