People v. Samspon, 2017 CO 100

On Jan. 12, 2016, Aurora PD Officer Darren Martinez questioned James Sampson in a small hospital room after Sampson arrived with knife wounds and initially claimed a stranger had attacked him.
Officer Martinez learned Sampson was a suspect in a separate domestic-violence incident and officers found an injured woman (Ms. R.) at the related apartment.
In the hospital, Martinez confronted Sampson, who initially repeated the mugging story but then admitted he had lied after Martinez said “we already know what happened.”
Martinez then read Miranda warnings; Sampson acknowledged understanding and agreed to talk; he gave narrative responses about the apartment incident.
The trial court found statements before Miranda were admissible (noncustodial) but suppressed statements after the Miranda advisement because the People failed to prove Sampson knowingly and voluntarily waived rights.
The People filed an interlocutory appeal; the Colorado Supreme Court reviewed whether Sampson was in custody for Miranda purposes during the hospital interview.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Sampson "in custody" for Miranda purposes during the hospital interview?	Conversation was noncustodial under totality of circumstances; Miranda not required.	Miranda applied once questioning turned accusatory and warnings followed; waiver after warnings was involuntary due to injuries/medication.	Court held Sampson was not in custody at any point; Miranda did not apply, and suppression order reversed.
Should giving Miranda warnings be considered in custody analysis?	Even if considered, the facts still show no custody.	Reading warnings can signal custodial status and bears on custody.	Court assumed without deciding warnings can be considered, but found no custody either way.
Did the People meet burden to prove a voluntary, knowing waiver of Miranda rights?	Not necessary if no custody; otherwise People argued waiver was valid.	Trial court: People failed to prove waiver was knowing/voluntary given injuries/unknown medications.	Court did not decide on waiver because it concluded no custody; reversal of suppression made waiver inquiry unnecessary.
Was the suppression order properly reviewable interlocutorily?	People certified requirements of C.A.R. 4.1(a); appeal permissible.	(Sampson challenged procedural sufficiency)	Court concluded interlocutory appeal requirements were satisfied.

Miranda v. Arizona, 384 U.S. 436 (establishing custodial-interrogation advisement requirement)
Berkemer v. McCarty, 468 U.S. 420 (public setting reduces coercive aura; traffic stops not custodial)
People v. Minjarez, 81 P.3d 348 (Colo. 2003) (hospital interrogation found custodial where officers were accusatory and positioned to restrict exit)
People v. Effland, 240 P.3d 868 (Colo. 2010) (hospital interview found custodial where defendant tried to end questioning and officers ignored him)
People v. Theander, 295 P.3d 960 (Colo. 2013) (hospital questioning not custodial where tone conversational, defendant not restrained, questioning ceased on request)
People v. Matheny, 46 P.3d 453 (Colo. 2002) (sets multi-factor Miranda custody test)
People v. Begay, 325 P.3d 1026 (Colo. 2014) (custody is mixed question reviewed de novo)
People v. Figueroa-Ortega, 283 P.3d 691 (Colo. 2012) (threat to charge later does not alone establish custody)
Sanchez v. People, 329 P.3d 253 (Colo. 2014) (standards for voluntary Miranda waiver)