Colorado v. Barraza
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The State brought an interlocutory appeal before the Supreme Court to challenge a district court's order to suppress Defendant Carlos Barraza's incriminating statements made prior to his first police interview at his home, and at a second interview at the police station after having been given his Miranda rights. Defendant was charged with retaliation against a witness or victim when he confronted residents of an apartment who called police on his friend, leading to the friend's arrest. The district court concluded that Defendant's initial statements were given while in custody, and subsequent statements were tainted by the failure to initially advise Defendant of his rights. Upon review, the Supreme Court held that, considering the totality of the circumstances, Defendant was not subjected to a custodial interrogation at the time he made the initial statements, and because statements made at the police station were not therefore fruit of the poisonous tree, the district court erred in suppressing both statements. Accordingly, the Supreme Court reversed the suppression order.
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