Supreme Court of Colorado
The People of the State of Colorado, Plaintiff-Appellant v. Wayne Michael Klinck, Jr., Defendant-Appellee
May 31, 2011259 P.3d 489
Summary
The court held that Klinck was not in Miranda custody during the brief porch interview because a reasonable person would not have viewed the circumstances as equivalent to formal arrest, and the trial court improperly relied on the officer's undisclosed intent to arrest him. The court also held that Klinck's later jailhouse statements, although obtained in violation of Miranda after he invoked counsel, were voluntary because the detectives' conduct did not overbear his will; the statements were therefore admissible for impeachment. The suppression order was reversed and the case was remanded for further proceedings.