The People of the State of Colorado, Plaintiff-Appellant v. Justin Ray Cline, Defendant-Appellee.

Summary

The court held that the trial court used the wrong standard for determining Miranda custody by asking whether Cline was free to leave rather than whether a reasonable person would view his freedom as restrained to a degree associated with formal arrest. Applying the totality of the circumstances, the court concluded that Cline was not in Miranda custody when he answered questions after police displayed the suspected drugs and paraphernalia, so no Miranda warning was required. The court reversed the suppression order and remanded for further proceedings. Justice Hood, joined by Chief Justice Coats and Justice Hart, dissented and would have found custody based on the ninety-minute detention and confrontation with direct evidence of an ongoing narcotics offense.