Colorado v. Spring

479 U.S. 564 (1987).

One-Sentence Takeaway: In order for a Miranda waiver to be valid, it is not required that the suspect be aware in advance of all the possible subjects of the interrogation.

Summary: Federal agents arrested Defendant in Missouri on a firearms charge.  Defendant signed a written waiver after he was advised of his Miranda rights.  During the interrogation that ensued, the focus of the questioning shifted from the firearms charge to an unsolved murder in Colorado.  Defendant confessed to the murder during the interrogation.

Defendant later challenged the admissibility of his confession by arguing that, at the sign he signed the waiver, Defendant was under the belief that he would be interrogated about the firearms charge and not about the murder.  He argued that, since the officers failed to inform him before he signed the waiver about the scope of the forthcoming interrogation, the waiver was invalid.

Although both the Colorado court of appeals and the Colorado supreme court agreed with Defendant, the United States Supreme Court reversed, holding that “[t]he Constitution does not require that a criminal suspect know and understand every possible consequence of a waiver of the Fifth Amendment privilege.  The Fifth Amendment’s guarantee is both simpler and more fundamental: A defendant may not be compelled to be a witness against himself in any respect.”

Thus, “a valid waiver does not require that an individual be informed of all information ‘useful’ in making his decision or all information that ‘might … affec[t] his decision to confess.’  ‘[W]e have never read the Constitution to require that the police supply a suspect with a flow of information to help him calibrate his self-interest in deciding whether to speak or stand by his rights.’ ” The Court reasoned that, while the information withheld by the police may go to the “wisdom” of the waiver, it does not take away from “[the waiver’s] essentially voluntary and knowing nature.”

Finding no evidence that Defendant “misunderstood the consequences of speaking freely to law enforcement officials,” the Court concluded that “the trial court was indisputably correct in finding that [Defendant’s] waiver was made knowingly and intelligently within the meaning of Miranda.

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