People v. Liggett, 334 P.3d 231

Police stopped Liggett after plate check linked vehicle to a missing person (his mother) and to Liggett as an armed-and-dangerous subject; he fled, crashed, was chased, surrendered and was handcuffed.
At the scene Liggett made several unprompted statements indicating severe mental-health themes (e.g., claims of being God, inability to tell right from wrong, that his mother was bipolar and may have committed suicide).
Officers transported Liggett to the sheriff’s office; he was interviewed unhandcuffed in a small room in two sessions totaling about five-and-a-half hours with breaks, water, breakfast and coffee.
Investigators read Miranda warnings; Liggett asked, “Can you call a public defender to be here now?” and was told “No.” The People conceded a Miranda violation.
During the interviews Liggett consistently denied killing his mother, maintained she committed suicide (potassium cyanide), repeatedly asserted the same delusional themes, and volunteered information at multiple points.
The trial court suppressed most post-Miranda statements as involuntary (and ordered a new sanity evaluation); the People appealed interlocutorily.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Liggett's post-warning statements were involuntary because police coercion overbore his will	People: although Miranda was violated, the statements were the product of Liggett's free choice and thus voluntary	Liggett: his request for counsel was an unequivocal invocation and investigators' conduct (denial of counsel, long custodial interrogation, early hour, mental condition) rendered subsequent statements involuntary	Court: Statements were voluntary under the totality of the circumstances; investigators did not overbear Liggett's will — suppression reversed
Whether denial of Liggett's expressed request for counsel made post-request statements involuntary	People: Miranda violation alone does not prove involuntariness; focus on coercion under due process	Liggett: investigators’ refusal to call counsel and the custodial setting made later statements involuntary	Court: Miranda violation acknowledged by People, but denial did not establish coercion sufficient to overbear will; voluntariness analysis controls and favors admissibility

Effland v. People, 240 P.3d 868 (Colo. 2010) (voluntariness requires statements be product of an essentially free and unconstrained choice)
People v. Raffaelli, 647 P.2d 230 (Colo. 1982) (coercive police tactics can render a confession involuntary)
People v. Parada, 553 P.2d 1121 (Colo. 1976) (specific promises by police can render statements involuntary)
People v. Quintana, 601 P.2d 350 (Colo. 1979) (promises of benefit tied to confession can make statements involuntary)