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Compos v. People.

2021 CO 19. No. 20SC143. Miranda Warnings—Routine Booking Question Exception—New Crime Exception—Party Presentation Principle.

April 12, 2021

In this case, the Supreme Court was asked to decide whether defendant’s Miranda rights were violated when, while in police custody, he was asked his name before receiving Miranda warnings. The Court was also asked to decide whether the division below erred in establishing a “new crime exception” to Miranda v. Arizona, 384 U.S. 436, 444, 478–79 (1966), and applying it here.

The Court held that the question about defendant’s name constituted a custodial interrogation, but, on the facts presented here, defendant’s response was admissible at trial because the question was akin to the type of routine booking question that has been deemed to be excepted from Miranda’s reach. The Court thus affirmed the judgment of the division below, albeit on other grounds. In light of this decision, the Court did not consider, and therefore vacated, the portion of the division’s judgment establishing, sua sponte, a new crime exception to Miranda.

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