State v. Medina, 440 P.3d 846

Victim found fatally stabbed; investigation placed Sergio Briseno Medina near the scene and linked him via phone records and fingerprints; he was arrested in Denver.
Detectives read Miranda warnings; Medina invoked his right to counsel.
Immediately after invoking counsel, Medina repeatedly asked detectives "what's going on," insisted he wanted answers, and volunteered facts about his relationship with the victim, drug use, and whereabouts.
Three days later detectives re-Mirandized Medina, confirmed he understood his rights, and conducted a second interview in which Medina made additional statements.
Medina moved to suppress statements from both interviews arguing his invocation of counsel was violated; the district court granted suppression.
The State appealed; the Utah Court of Appeals reversed, holding Medina initiated the post-invocation communications, waived counsel knowingly and voluntarily, and the second interview was also permissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements after Medina invoked counsel should be suppressed	State: Medina initiated further discussion and thus validly waived his right to counsel	Medina: His post-invocation remarks were routine/confused questions and did not waive the right to counsel	Reversed: Medina initiated substantive discussion about the investigation, so waiver applies
Whether waiver was knowing and intelligent	State: Medina’s unsolicited explanations and willingness to answer show knowing waiver	Medina: Waiver was not knowing; detectives should have clarified invocation	Reversed: Totality shows Medina understood rights and deliberately chose to speak
Whether statements were voluntary	State: No coercion; statements were products of free choice	Medina: Statements involuntary absent further evidence	Reversed: No police coercion; interrogation record supports voluntariness
Admissibility of second interview statements	State: Second interview valid because (1) first-waiver carried over and (2) detectives re-Mirandized before second interview	Medina: Second statements tainted by first-interview violation	Reversed: Second Miranda recitation and short interval made second interview admissible

Miranda v. Arizona, 384 U.S. 436 (establishes Miranda rights requirement for custodial interrogation)
Davis v. United States, 512 U.S. 452 (requests for counsel must be unambiguous to invoke Edwards protections)
Edwards v. Arizona, 451 U.S. 477 (police must cease interrogation after unambiguous invocation of counsel unless defendant initiates further communication)
Maryland v. Shatzer, 559 U.S. 98 (14-day safe-harbor rule for reinitiating interrogation after invocation of counsel)
Berghuis v. Thompkins, 560 U.S. 370 (knowing and voluntary waiver may be inferred from a suspect’s actions and words)
State v. Moore, 697 P.2d 233 (Utah) (three-factor test for admissibility when defendant initiates post-invocation discussion)
State v. Dahlquist, 931 P.2d 862 (Utah Ct. App.) (distinguishes innocuous post-invocation inquiries from waiver-producing initiation)
State v. Gardner, 428 P.3d 58 (Utah Ct. App.) (post-invocation unsolicited narrative about the crime can constitute waiver)
Oregon v. Bradshaw, 462 U.S. 1039 (totality of circumstances governs whether waiver is knowing and intelligent)