v. Compos, 2019 COA 177

Vincent Compos was arrested at a victim's home after the victim reported he pointed a gun and violated an active protection order; at the scene he gave at least two false identifiers, including telling an officer while handcuffed that his name was "John Rocha" and providing Rocha's birth date.
Police later discovered the identity was false; Compos was charged with felony menacing, criminal impersonation, false reporting to authorities, violation of bail, and violation of a protection order.
The trial was bifurcated; the jury acquitted on menacing but convicted Compos of criminal impersonation and the lesser offense of false reporting; Compos later pleaded guilty to one protection-order violation in a plea deal dismissing remaining counts.
Before trial Compos moved to suppress the false-name statement under Miranda; the trial court denied suppression, treating the question as a routine booking/identification question or otherwise admissible; parties agreed Compos was in custody but disputed whether the officer's question was "interrogation."
On appeal the Colorado Court of Appeals assumed, without deciding, that Miranda was violated but held suppression unnecessary because Compos’s false-name response constituted a new, independent crime and therefore was admissible; the court also denied a mistrial claim based on fleeting references to prior bad acts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Suppression of false-name statement under Miranda	Statement admissible (booking/administrative ID question; new-crime exception)	Question was custodial interrogation without Miranda; statement must be suppressed	Even assuming Miranda violation, statement admissible because the false identity was a new crime (new-crime exception)
Whether officer's question was custodial interrogation (booking exception)	Routine booking/identification question not subject to Miranda	Express question was interrogation outside booking exception	Court did not decide; assumed Miranda violation for purposes of appeal and relied on new-crime rationale
Mistrial for victim's references to prior bad acts	Statements were ambiguous, fleeting, and not substantially prejudicial	Testimony violated CRE 404(b) and warranted mistrial	No abuse of discretion denying mistrial; references were ambiguous/fleeting, jury acquitted on one count, and proper evidence of prior misconduct existed
Voluntariness of the false-name statement	Statement was admissible and not challenged as involuntary	Compos did not raise voluntariness challenge on appeal	Voluntariness not contested; admissibility addressed on new-crime grounds

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings requirement for custodial interrogation)
Rhode Island v. Innis, 446 U.S. 291 (1980) (defines interrogation to include express questioning and its functional equivalent)
Pennsylvania v. Muniz, 496 U.S. 582 (1990) (recognizes routine booking-question exception to Miranda for biographical data)
People v. Doke, 171 P.3d 237 (Colo. 2007) (adopts new-crime exception in Fourth Amendment context)
United States v. Kirk, 528 F.2d 1057 (5th Cir. 1976) (statement that itself constitutes a crime need not be suppressed under Miranda)
United States v. Mitchell, 812 F.2d 1250 (9th Cir. 1987) (reiterates that committing a crime differs from making an inculpatory statement for exclusionary-rule purposes)
United States v. Pryor, 32 F.3d 1192 (7th Cir. 1994) (false identification given after arrest can be admitted despite challenges under Fourth or Fifth Amendment exclusionary rules)
People v. Breidenbach, 875 P.2d 879 (Colo. 1994) (discusses scope and exceptions to Miranda suppression)
People v. Aarness, 150 P.3d 1271 (Colo. 2006) (appellate courts may affirm on any record-supported grounds)