Colorado v. Spring

Colorado v. Spring Case Brief

United States Supreme Court
479 U.S. 564 (1987)

ISSUE: Must a suspect be informed of all of the possible subjects of the interrogation as a necessary precondition to his waiver of his Miranda rights being voluntary and knowing?
HOLDING: No, a suspect's awareness of all the possible subjects of questioning in advance of interrogation is not relevant to determining whether the suspect voluntarily, knowingly, and intelligently waived his 5th Amdt. privilege.
  • Spring and a companion shot and killed a man during a hunting trip in Colorado
  • An informant told the ATF that Spring was engaged in interstate transportation of stolen firearms and that Spring had discussed participation in the killing
  • Agents set up an undercover buy from Spring and then arrested him
  • Spring was advised of his rights 2x, and he then signed a waiver of those rights
  • During the 1st round of questioning, D was not told that he would be questioned about the Colo. homicide, but he did say that "I shot another guy once"
  • During the 2nd interrogation with Colo. police, D again waived his rights and made a full confession
  • Trial Ct. did not find that Spring's waiver was invalid despite not being told of all the topics but did exclude the "shot another guy once" statement as irrelevant
  • Ct. App. reversed holding that the agents had a duty to inform Spring that he was a suspect or readvise him of his rights before questioning him about the murder
  • Colo. Sup. Ct. affirmed
  • Waiver was voluntary: There is no doubt that Spring's decision to waive his 5th Amdt. privilege was voluntary
    • Allegation that police failed to supply him with certain info is not one of the traditional indicia of coercion
    • Since there was no indication that his will was overborne or his capacity critically impaired because of coercive police conduct, he waiver was voluntary
  • No trickery: Court has never held that mere silence by law enforcement officials as to the subject matter of an interrogation is "trickery" sufficient to invalidate a suspect's waiver
    • Valid waiver does not require that an individual be informed of all info "useful" in making his decision or that might affect his decision
    • Thus, officials failure to inform Spring of the subject matter of the interrogation could not affect his decision to waive his 5th Amdt. privilege
  • Often a suspect will want to know what he's going to be questioned about before deciding whether to talk to the police. But under Colorado v. Spring, he is not entitled to know all possible subjects of interrogation. Thus if the police say they're going to question someone about a robbery and then segue into questions about a murder, a Miranda waiver is still valid in the murder-context.
  • Practically this makes some sense: if the Court made a waiver crime-specific, what would define a "crime?" Sure robbery and murder sound different, but what about a robbery-murder? You see the conundrum.
  • However, it is difficult to logically reconcile the Court's decision. How a person can knowingly waive his or her rights without knowing highly relevant details of the questioning is difficult to comprehend. But Spring is the law.
  • Moran v. Burbine: D was taken into custody and, unbeknownst to him, an attorney hired by D's sister called the police and told them that she intended to represent D in the event of any questioning. Officers said that D would not be questioned until the next day, but they questioned him that night after giving D his Miranda rights.
    • HELD, D's waiver was valid, as the interactions between the police and an attorney have no impact on the validity of D's waiver
    • Police are not required to supply a suspect with a flow of info to help him calibrate his self-interest in deciding whether to speak or stand by his rights
    • One's attorney cannot one's rights for him -- police have no obligation to tell D that there's an atty outside the door that wants to represent him
  • Connecticut v. Barrett: D said that he would orally answer questions but wouldn't write them out
    • HELD, D voluntarily and knowingly waived his rights
    • A D has a choice between speech and silence; choosing speech = waiver


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