Patrick Frazee, Petitioner: v. the People of the State of Colorado.

Summary

The court held that the Department of Human Services caseworker was neither a law enforcement officer nor an agent of law enforcement when she questioned Frazee. Because Miranda therefore did not apply, the court affirmed the judgment on grounds different from those relied on by the court of appeals and declined to decide whether Frazee was in Miranda custody. The court applied a totality-of-the-circumstances analysis focusing on the caseworker's role, authority, purpose, contact with law enforcement, and conduct during the interview.