People v. Sanders Jr.

2023 CO 62. No. 23SA187. Criminal Law—Custodial Interrogation—Miranda Warnings—Statements by Accused—Voluntariness of Statement—Evidence Wrongfully Obtained—Appellate Brief Defects.

December 18, 2023

The Supreme Court held that where a district court orders evidence suppressed on the separate bases of custody and voluntariness, an appellant challenging that order must address both bases for suppression to prevail on appeal. In doing so, it is the appellant’s responsibility to set forth the grounds upon which its argument relies, with citations to the relevant authorities and parts of the record. Here, the People challenged the district court’s custody determination but failed to address the court’s voluntariness determination, which established an independent basis for suppression. Accordingly, the Court determined it must uphold the district court’s suppression order.