People v. Brandon Bohler
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Brandon Mason Bohler was charged with first-degree murder after stabbing his roommate to death. He pleaded not guilty by reason of insanity. During his arrest, Bohler made statements to the police which were later suppressed by the district court. The court ruled that Bohler was in custody for Miranda purposes when he made the statements, and thus, they should have been preceded by a Miranda warning.
The People of the State of Colorado appealed the district court's decision to suppress Bohler's statements. They argued that Bohler was not in custody when he made the statements, and therefore, a Miranda warning was not required. The appeal was brought before the Supreme Court of the State of Colorado.
The Supreme Court of the State of Colorado reversed the district court's decision. The court determined that Bohler was not in custody when he made the statements. The court reasoned that a reasonable person in Bohler's position would not have believed himself to be deprived of freedom of action to the degree associated with a formal arrest. Therefore, the court concluded that the district court erred in suppressing Bohler's statements, and remanded the case for further proceedings consistent with its opinion.
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