Sanchez v. People, 2014 CO 56

Sanchez was convicted of first-degree murder in Colorado for a 2006 New Mexico arrest; the case on appeal challenged suppression of statements made to New Mexico police as Miranda violations.
The suppression motion argued Sanchez was not adequately advised about appointed counsel and could not understand if he would be charged for an attorney.
The district court found the officer adequately advised Sanchez that if he could not afford counsel, one would be appointed; waiver was valid.
The court of appeals affirmed, agreeing the advisement conveyed the indigent-counsel right without charging liability for costs.
The Supreme Court decided to affirm, clarifying that Miranda does not require disclosure of ultimate liability for attorney costs, and that a fully effective equivalent of Miranda warnings suffices.
The concurrence by Justice Hood would not join the majority's dicta on potential future costs and would focus on the explicit adequacy of the advisement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miranda warnings were adequate regarding appointed counsel for indigents	Sanchez argued warnings failed to convey free-appointed counsel	State/People argued warnings were fully effective equivalents	Yes; warnings were adequately conveyed (fully effective equivalent)
Whether the waiver of Miranda rights was knowing and intelligent given the form omission	Sanchez contends waiver was not fully informed due to incomplete form	Waiver valid if suspect understands rights and provides voluntary waiver	Waiver was knowing and intelligent despite form omission
Whether Miranda requires notification of no-cost ultimate liability for attorney fees	Issue framed around cost liability disclosure	Miranda does not require disclosure of ultimate cost liability	Not required; advisement of appointment if indigent suffices

Miranda v. Arizona, 384 U.S. 436 (1966) (required warnings and effective equivalents; indigent counsel must be available)
Duckworth v. Eagan, 492 U.S. 195 (1989) (adequacy of warnings evaluated by conveyance of rights)
Prysock, 453 U.S. 355 (1981) (no talismanic incantation required; adequate conveyance of rights)
Moran v. Burbine, 475 U.S. 412 (1986) (suspect need not understand every consequence of waiver)
Spring, 479 U.S. 564 (1987) (knowing and intelligent waiver requires understanding of Miranda safeguards)
Berghuis v. Thompkins, 560 U.S. 370 (2010) (waiver can be inferred from conduct; explicit waiver not required)
Colorado v. Connelly, 479 U.S. 157 (1986) (voluntariness standard for confession)