Adam Douglas Densmore, Petitioner: v. the People of the State of Colorado. Respondent:

Summary

The court held that whether a Department of Human Services caseworker conducting a custodial interview acted as an agent of law enforcement must be determined under a totality-of-the-circumstances test that considers both objective and subjective factors. Applying that test, it concluded that the caseworker's child-welfare purposes, lack of police direction or participation, and lack of intent to obtain incriminating information meant that Miranda warnings were not required. The court therefore affirmed the court of appeals' judgment upholding the denial of Densmore's suppression motions.