Supreme Court of Colorado

Kimberlie Deann Verigan, Petitioner v. the People of the State of Colorado, Respondent.

June 11, 2018420 P.3d 247

Summary

The court held that the controlling rule from the fractured two-step-interrogation decision is the narrower approach requiring suppression only when police deliberately use a prewarning interrogation to undermine later Miranda warnings and fail to take curative measures. Because the officers here did not deliberately employ that strategy, the ordinary voluntariness framework applied, making Verigan's postwarning statements admissible. The court therefore affirmed the court of appeals' judgment.