Colorado v. Cline

In an interlocutory appeal, the issue presented for the Colorado Supreme Court’s review centered on whether the trial court erred in suppressing a statement made by defendant Justin Cline after a search of his residence by his parole officer and a member of the Craig, Colorado Police Department. The search netted a zippered pouch containing drug paraphernalia that tested positive for methamphetamine. The trial court found that when Corporal Grant Laehr confronted Cline with the zippered pouch and questioned him, Cline was “effectively under arrest” and “not free to leave.” The trial court reiterated that once Cline was confronted with the zippered pouch, “a reasonable person in [his] position would not have believed he was free to leave.” The trial court ruled that any subsequent questions should have been preceded by an advisement pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Since no such advisement was provided, the trial court suppressed Cline’s statements. The Supreme Court reversed, finding the trial court applied the wrong legal standard. “[W]hen viewed in conjunction with the other circumstances present, it is insufficient to warrant a determination that Cline was in custody and that Corporal Laehr was required to read him his Miranda rights. Because the trial court applied the wrong legal standard and treated as dispositive the fact that Corporal Laehr confronted Cline with the zippered pouch, we reverse its suppression order and remand for further proceedings.” View "Colorado v. Cline" on Justia Law