Background

• People appealed the district court's suppression of statements by the defendant to a police detective, challenging custodial interrogation without Miranda warnings.
• Defendant was charged with burglary, criminal mischief, and theft related to a restaurant break-in where he worked as a cook.
• Two police contacts were referenced: Sept. 13 (at the scene) and Sept. 28 (outside his apartment) after video evidence identified him.
• Video footage from a church surveillance camera showed the burglary sequence and the defendant associated with it.
• Trial court found the Sept. 28 interview began as non-custodial but became accusatory during the interview, leading to suppression of Sept. 28 statements.
• appellate court held the defendant was not in custody for Miranda purposes during the Sept. 28 statements, reversing the suppression.

Issues

Key Cases Cited

• Berkemer v. McCarty, 468 U.S. 420 (1984) (custody threshold requires more than a stop)
• Minnesota v. Murphy, 465 U.S. 420 (1984) (custody determination depends on degree of liberty infringement)
• California v. Beheler, 463 U.S. 1121 (1983) (custody analysis includes old vs. new confinement context)
• People v. Klinck, 259 P.3d 489 (Colo.2011) (custody determination analyzed in totality of circumstances)
• People v. Matheny, 46 P.3d 453 (Colo.2002) (factors informing whether an encounter is consensual or investigatory stop)
• People v. Breidenbach, 875 P.2d 879 (Colo.1994) (drawn guns/physical restraints signaling arrest)
• People v. Polander, 41 P.3d 698 (Colo.2001) (noting that warning or release context affects custody interpretation)