People v. Smiley.

2023 CO 36. No. 22SA350. Custodial Interrogation—Miranda Rights—Self-Incrimination—Waiver—Voluntariness.

June 12, 2023

In this interlocutory appeal, the Supreme Court reviewed the trial court’s order suppressing Smiley’s inculpatory statements made during a stationhouse interview. The trial court concluded that Smiley’s waiver of his rights under Miranda v. Arizona, 384 U.S. 436 (1966), was involuntary. Based on the totality of the circumstances, including affirmative misrepresentations by the detectives immediately before they elicited the waiver, the Court affirmed the trial court’s order.