Supreme Court of Colorado

Furmen Lee Leyba v. the People of the State of Colorado

June 21, 2021489 P.3d 728

Summary

The court held that a suspect who has invoked the right to counsel may immediately reinitiate discussion of the investigation after police stop questioning, because no minimum waiting period is required. Leyba's unsolicited comments showed a willingness to discuss the investigation, and the detective's brief responses did not constitute continued interrogation. The court therefore concluded that Leyba revoked his prior request for counsel, validly waived his rights, and had no basis to suppress his statements.