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People v. McIntyre
325 P.3d 583
Colo.
2014
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Background

  • Meclntyre was accused by his niece, J.M., of sexual assault in 2007; the allegations led to state charges in 2012.
  • Detective Otto conducted an initial interview with Miranda warnings; Melntyre waived rights and spoke for about 44 minutes.
  • A week later, Deputy Porter conducted a lie detector examination with Melntyre, after reading Miranda warnings and obtaining consent.
  • During the lie detector process, Porter attempted to tailor questions and emphasized voluntariness and that Melntyre could leave at any time.
  • Melntyre ultimately confessed to some touching during the interview, and later asked for a lawyer; Detective Otto did not conduct a follow-up interview.
  • The trial court granted suppression of the statements from the second interview but denied suppression of the first; the People appealed intermediately.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Deputy Porter coerced Melntyre into statements Melntyre’s will was overborne by coercive tactics Totality of circumstances shows voluntariness No coercion; statements voluntary
Whether Miranda warnings and advisory rights were properly applied Rights were validly given and waived Waiver was valid given circumstances Miranda warnings properly given and rights waived
Whether the trial court erred by focusing on limited Medina factors Courts must consider coercion indicators Totality of circumstances controls Totality of circumstances supports voluntariness

Key Cases Cited

  • Zadran v. People, 314 P.3d 830 (Colo. 2013) (voluntariness requires overbearing will under totality of circumstances)
  • People v. Ramadon, 314 P.3d 836 (Colo. 2013) (totality-of-circumstances framework for voluntariness)
  • People v. Medina, 25 P.3d 1216 (Colo. 2001) ( Medina factors guiding voluntariness inquiry)
  • Parada v. People, 533 P.2d 1121 (Colo. 1975) (limitations on statements implying immunity or lack of punishment)
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Case Details

Case Name: People v. McIntyre
Court Name: Supreme Court of Colorado
Date Published: May 27, 2014
Citation: 325 P.3d 583
Docket Number: Supreme Court Case No. 13SA235
Court Abbreviation: Colo.