Supreme Court of Colorado
Patrick Frazee, Petitioner: v. the People of the State of Colorado.
February 10, 20252025 CO 7
Summary
The court held that the Department of Human Services caseworker who questioned Frazee was neither a law enforcement officer nor an agent of law enforcement for Miranda purposes. Because Miranda therefore did not apply, the court affirmed the judgment below on different grounds and did not decide whether Frazee was in custody under Miranda. The court rejected Frazee's proposed bright-line rule requiring warnings whenever a caseworker questions a detained parent about potentially criminal allegations.