State v. Garcia, 299 Conn. 39

A Waterbury store robbery in January 2007 led to defendant Garcia being identified as a suspect by a witness and later questioned by police.
Garcia, Spanish-speaking, confessed at the police station with bilingual Detective Tirado translating and reducing the statement to writing in English.
Garcia challenged the written statement, arguing lack of custody, involuntariness, coercion, and improper translation/authentication.
Trial court found Garcia not in custody, his rights were explained in Spanish, and his waiver was knowing, voluntary, and intelligent; statement admitted.
On appeal, Garcia argued coercion (finger injury alleged), improper translation (bilingual officer rather than independent interpreter), and equal protection concerns under § 46a-33a.
Connecticut Supreme Court affirmed, holding the statement admissible, properly authenticated, and translation adequate under Colon/roa Rosa framework.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Custody and Miranda waiver validity	Garcia argues he was in custody and rights were not validly waived.	Garcia contends Miranda safeguards were not properly observed; waiver not voluntary.	Waiver valid; custodial status at questioning does not bar admissibility if rights waived.
voluntariness of the statement	Garcia asserts coercion; injury evidence suggests overbearing police conduct.	Garcia claims coercive interrogation led to an involuntary confession.	Court affirms voluntariness; no credible coercion evidence; credibility findings upheld.
Interpreter/translation adequacy	Garcia argues lack of disinterested interpreter undermines reliability.	Garcia claims translation by a bilingual officer compromised fairness.	Translation authenticated under Colon; no constitutional violation; no mandatory third-party interpreter required.
Equal protection challenge to interpreter certification	Garcia claims non-English speakers are similarly situated to deaf/hearing impaired and thus protected.	Garcia asserts unequal treatment under § 46a-33a; remedy should be suppression.	No equal protection violation; no suppression warranted absent harm; non-English speakers not identically situated.

State v. Wallace, 290 Conn. 261 (2009) (Miranda warnings enhance voluntary decision to speak)
State v. Barrett, 205 Conn. 437 (1987) (Miranda rights importance in voluntariness analysis)
State v. Santiago, 245 Conn. 301 (1998) (Miranda safeguards as essential to free choice)
State v. Fields, 265 Conn. 184 (2003) (per se inadmissibility where physical violence accompanies confession)
State v. Rosa, 170 Conn. 417 (1976) (issues of authentication of translated written confession; limits on translation procedures)
State v. Colon, 272 Conn. 106 (2004) (Colon distinguished Rosa; translator verification and cross-examination suffice for authentication)
State v. Carpenter, 275 Conn. 785 (2005) (broad discretion on admissibility of evidence; standard of review)