Colorado v. Spring

In Colorado v. Spring, 479 U.S. 564 (1987), the victim, Daniel Walker, was shot and killed in February 1979 during a hunting trip in Colorado. Shortly thereafter, an informant told agents of the Bureau of Alcohol, Tobacco, and Firearms (ATF) that the defendant, Spring, was engaged in the interstate transportation of stolen firearms and that the defendant had discussed his participation in the Colorado killing. Based on the information received, ATF agents set up an undercover operation to purchase firearms from the defendant. On March 30, 1979, they arrested the defendant during an undercover purchase in Kansas City, Missouri. An ATF agent advised defendant of his Miranda rights at the scene of the arrest and he was re-advised a second time after he was transported to the ATF office in Kansas City. Defendant signed a written form stating that he understood and waived his rights and that he was willing to make a statement and answer questions. The agents first questioned defendant about the firearms transactions that led to his arrest. They then asked defendant if he had a criminal record. The defendant admitted that he had a juvenile record for shooting his aunt when he was ten years old. The agents then asked the defendant if he had ever shot anyone else and defendant admitted that he had. The agents then began questioning defendant about the Colorado killing which he denied and the interrogation ceased. He was subsequently questioned by Colorado authorities and confessed to the murder. The defendant sought to have the later confession suppressed on the basis that it was the illegal "fruit" of his March 30, 1979, statement wherein he made an invalid waiver of his Miranda rights. The Colorado Court of Appeals agreed with the defendant and reversed his conviction which the Colorado Supreme Court affirmed. The U.S. Supreme Court held that a suspect's awareness of all the possible subjects of questioning in advance of interrogation is not relevant to determining whether the suspect voluntarily, knowingly, and intelligently waived his Fifth Amendment privilege. Spring, 479 U.S. at 577. It found that the defendant's decision to waive his Fifth Amendment privilege was voluntary; that there was no coercion of a confession by physical violence or other deliberate means calculated to break his will. Id. at 573-574. The Court also found that there was no doubt that the defendant's waiver was knowingly and intelligently made, that is, that he understood that he had the right to remain silent and that anything he said could be used as evidence against him. Id. at 574. It observed that the Constitution does not require that a criminal suspect know and understand every possible consequence of a waiver of the Fifth Amendment privilege. Id. The Court stated that the Fifth Amendment's guarantee is both simpler and more fundamental: a defendant may not be compelled to be a witness against himself in any respect. Id. In sum, agents of the Bureau of Alcohol, Tobacco and Firearms (ATF) were told by an informant that Spring was engaged in interstate transportation of stolen firearms and had also participated in a Colorado murder. The agents arrested Spring and advised him of his Miranda rights. They began by questioning him about the firearms transactions, and later questioned Spring about whether he had shot a man in Colorado. Spring later confessed to Colorado law enforcement officers to the murder and was charged in Colorado state court with first degree murder. Spring contended that his statements about the Colorado murder to the ATF agents should be suppressed. He argued that his Miranda waiver was invalid because he was never informed that he was going to be questioned about the murder. He claimed that his later statement to the Colorado police was an illegal "fruit" of the earlier statement. The Colorado Supreme Court accepted Spring's argument, suppressing the confession. But the United States Supreme Court reversed. The United States Supreme Court held that the failure of the law enforcement officers to inform Spring of matters they intended to interrogate him about did not invalidate his Miranda waiver.