Colorado v. Samspon

Defendant James Sampson spoke with a police officer while Sampson was in a hospital for treatment of knife wounds. Sampson told the officer someone the street had stabbed him while trying to rob him, and a Good Samaritan drove him to the hospital. The officer ran Sampson’s name in APD’s information database and learned Sampson was a suspect in a September 2015 domestic violence assault case that allegedly occurred at an address near where Sampson said he was picked up. The officer then sent officers to the address to make sure it wasn’t a crime scene. When the officers arrived at the address, they saw what looked like blood outside the apartment door. No one answered the door, so they forced entry. Inside they found Ms. R. with a stab wound on her thigh. Ms. R. told the officers that Sampson had attacked her with a bat, and she had defended herself with a knife. At the hospital, the officer told Sampson that officers were in contact with Ms. R. and that he knew what had happened at the apartment. At first, Sampson stuck to his original story, but after the officer said, “[L]ook, we already know what happened,” Sampson admitted he had lied. After this admission, the officer read Sampson a Miranda advisement, the sufficiency of which was not in dispute. Sampson acknowledged that he understood his rights, and he agreed to answer questions. Sampson’s statements were at issue in this appeal: whether Sampson was in custody when he spoke to the officer. The trial court ruled Sampson was not in custody for Miranda purposes until the officer gave Sampson a Miranda advisement. Finding the State failed to prove Sampson made a voluntary waiver of his Miranda rights, the trial court suppressed the statements Sampson made after the advisement. The State appealed, and the Colorado Supreme Court reversed, finding defendant was not in custody at any point during his conversation with the officer at the hospital. Therefore, Miranda did not apply, and the trial court was reversed. View "Colorado v. Samspon" on Justia Law