The Colorado Supreme Court issued its opinion in People v. N.A.S. on Monday, June 30, 2014.
Juvenile Custody Under Miranda—Voluntariness and Coercion.
In this interlocutory appeal, the People sought review of the trial court’s order suppressing statements of the juvenile defendant. The trial court found that defendant was in custody when he made the statements; that he did not waive his Miranda rights knowingly, voluntarily, or intelligently; and that the statements were involuntary.
The Supreme Court held that, in light of the totality of the circumstances, defendant was not in custody when he made the statements, and he spoke voluntarily. Accordingly, the Court reversed the trial court’s suppression order and remanded for proceedings consistent with this opinion.
Summary and full case available here.