Colorado v. Clark
Annotate this CaseThe State sought interlocutory review of a trial court decision finding Bradley Clark was in custody so as to trigger "Miranda" when he made statements to law enforcement during the execution of a search warrant prior to his formal arrest. The trial court granted Clark's motion to suppress the statements. Firefighters were dispatched to a grocery store in Durango, Colorado to address a fire inside the store. They determined the fire had been set intentionally, and requested police department assistance. Based on review of security camera footage, police pinpointed the suspect who walked from the area of the fire to the self-checkout lines. At his residence, detectives in plain clothes, and one officer in uniform, discussed Clark's whereabouts through the door. They asked Clark if he would be willing to discuss his whereabouts outside; Clark acquiesced, wishing to avoid alarming his wife and children. Notwithstanding prior statements that he knew nothing about the incident, Clark said that he knew about the fire because he had read about it on the internet and that he and his wife had “joked about it.” Having heard Clark contradict himself a number of times, Detective Newman told Clark that there were video cameras in the store and that based on the footage, Clark was the suspect. While Detective Newman spoke with Clark outside, the other officers searched the home. Detective Newman testified that he did not place Clark in handcuffs while the two were talking, nor did he put any other kind of restraints on Clark or otherwise limit Clark's movement. The detective further testified he did not give Clark a Miranda advisement, stating that once Clark was under arrest, he did not question Clark further. Clark pleaded not guilty, resulting in the motion to suppress at issue here. The Colorado Supreme Court determined Clark was not in custody for Miranda purposes when the detective questioned him outside his home regarding the fire that occurred at the grocery store. The trial court erred in suppressing statements Clark made at the time.
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