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Colorado v. Spring | 479 U.S. 564 (1987)

Anybody who’s ever seen a cop show knows that arrested suspects who waive their right to remain silent will often have their own statements used against them. But reality sets in when prosecutors must show that a suspect’s waiver is valid. Just how much does a suspect have to know for the waiver to be valid? The United States Supreme Court considered that question in Colorado versus Spring.

John Spring shot and killed Donald Walker during a hunting trip in Colorado. Shortly thereafter, agents of the Bureau of Alcohol, Tobacco, and Firearms, or the ATF, were informed that Spring sold stolen guns and had talked about killing someone in Colorado. On March 30th, 1979, agents arrested Spring in Kansas City, Missouri.

An ATF agent at the scene read Spring his Miranda rights. At the bureau’s office, agents again advised Spring that he could stop his questioning anytime or stop until he had an attorney present. Spring signed a form stating that he understood and waived his rights and was willing to answer questions.

ATF agents asked Spring about his gunrunning, then later asked him if he’d ever shot anyone. Spring admitted that he’d once shot someone. But when ATF agents asked him if he’d shot Walker in Colorado, Spring said no, and the interview ended.

Nearly two months later, on May 26th, Colorado police visited Spring in his Kansas City jail, read him his Miranda rights, and again, Spring signed a form saying that he understood and waived his rights. When asked about Walker’s murder, Spring stated that he wanted to, quote, “get it off his chest,” unquote, then freely confessed to Walker’s murder. Spring never asked to end the interrogation, nor did he request counsel. The officers prepared a written summary of the interview, which Spring read, edited, then signed.

At his Colorado murder trial, Spring moved to suppress both statements, arguing that his March 30th Miranda waiver was invalid because he didn’t know ATF agents were going to ask him about Walker’s murder. The trial court denied his motion, and Spring was convicted. The Colorado Court of Appeals reversed, concluding that Spring’s March 30th Miranda waiver was invalid, and that his May 26th statement was the fruit of the poisonous tree, making both statements inadmissible. The Colorado Supreme Court affirmed, and the United States Supreme Court granted cert.

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