Colorado v. Klinck

The State appealed a trial court order that suppressed statements made by Defendant Wayne Klinck during his initial interview by police. Responding to a domestic disturbance report, police arrived at Defendant's girlfriend's house. They asked Defendant to remain on the porch while the officers interviewed the girlfriend. Shortly thereafter, an officer spoke with Defendant, and when the officer determined he had probable cause, he placed Defendant under arrest. Defendant was advised of his Miranda rights and he invoked his right to counsel. Detectives re-contacted and interviewed Defendant in jail, and at that time Defendant waived his Miranda rights and provided additional information. The trial court suppressed the statements Defendant made on the porch prior to being placed under arrest. Upon consideration of the arguments and the applicable legal authority, the Supreme Court reversed the lower court's decision. The Court found that Defendant was not in custody during his initial interview on the porch. The Court remanded the case to the trial court for further proceedings.