Colorado v. Luna-Solis
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The State filed an interlocutory appeal to the Supreme Court seeking relief from a district court order that suppressed statements of Defendant Jesus Luna-Solis as well as certain DNA evidence. Although the court found that the statements in question were voluntary and made after an effective waiver of Miranda rights, it nevertheless suppressed them on the grounds that the Sixth Amendment barred the police from questioning defendant without counsel present. The court suppressed the DNA evidence on grounds that police in the execution of a Crim. P. 41.1 order of a County Court, sought the order for the benefit of the prosecution in this case, and that after filing a motion to admit evidence of an uncharged assault, the prosecution was permitted to acquire non-testimonial identification evidence from defendant, even to verify his identity as a perpetrator in the assault, only according to Crim. P. 16 II (a)(2), governing discovery in this case. Because defendant's Miranda waiver effectively waived his right to counsel as guaranteed by not only the Fifth but also the Sixth Amendment, the Supreme Court concluded that the district court erred in suppressing statements as a violation of the defendant's Sixth Amendment right to counsel. Because Crim. P. 16 II imposes disclosure obligations on criminal defendants without simultaneously barring the use of evidence acquired through otherwise lawful investigation, the Court also found that the district court erred in finding a discovery violation and excluding DNA evidence. The district court's suppression order was reversed and the case remanded for further proceedings.
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