The People of the State of Colorado v. Erick Wozbely Figueroa-Ortega

Summary

The court reversed an order suppressing the defendant's statements because the detective's twenty-minute, public questioning outside the defendant's apartment did not amount to custodial interrogation. Although the detective confronted the defendant with incriminating evidence and said he would be charged, those circumstances did not establish the degree of restraint associated with a formal arrest. The court held that the defendant was not in custody when he made the statements, so Miranda warnings were not required.