2021 CO 19
Colo.2021Background
- Compos threatened his ex-girlfriend with a gun at her home; she called 911 and fled. Police arrived, tased and handcuffed Compos, placing him in custody.
- About five minutes after custody, an officer asked Compos his name before giving Miranda warnings; Compos responded falsely "John Rocha."
- Prosecutors charged Compos with criminal impersonation (false name) and violating a protection order; Compos moved to suppress the statements as unwarned custodial interrogation.
- The trial court denied suppression; a jury convicted Compos of impersonation (and he later pled to the protection-order violation).
- A division of the court of appeals affirmed but, sua sponte, adopted a new "crime exception" to Miranda; the Colorado Supreme Court granted certiorari.
Issues
| Issue | Plaintiff's Argument (Compos) | Defendant's Argument (People) | Held |
|---|---|---|---|
| Whether asking a person his name after taking him into custody is an interrogation implicating Miranda | Questioning after custody was an interrogation and required Miranda warnings; statements should be suppressed | Asking name was a non-investigative, administrative/booking question exempt from Miranda | The question was a custodial interrogation, but the answer was admissible under the routine booking-question exception; Colorado adopts that exception |
| Whether the court of appeals properly created a new "crime exception" to Miranda | Division erred: creating a new exception sua sponte and deciding an issue not presented violates party-presentation principles | (People did not press a new-crime rule; they relied on booking-question exception) | The Supreme Court vacated the division's creation of a new crime exception and left the issue for another day |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishes custodial-interrogation warnings requirement)
- Pennsylvania v. Muniz, 496 U.S. 582 (questions about identity in custody can be interrogation; booking-question exception discussed)
- People v. Doke, 171 P.3d 237 (Colo. 2007) (new-crime exception discussed in Fourth Amendment context)
- United States v. Edwards, 885 F.2d 377 (7th Cir. 1989) (supports routine booking-question exception for identity questions)
- United States v. Parra, 2 F.3d 1058 (10th Cir. 1993) (distinguishes identity questions used for investigation—booking exception does not apply)