Colorado v. Spring Case Brief

Facts of the Case

“In February 1979, John Leroy Spring and a companion shot and killed Walker during a hunting trip in Colorado. Thereafter, based on information received from an informant as to Spring’s involvement in the interstate transportation of stolen firearms, agents of the Bureau of Alcohol, Tobacco, and Firearms (ATF) set up an undercover purchase of firearms from Spring, and on March 30, 1979, arrested him. After being advised of hisrights, Spring signed a statement that he understood and waived his rights and was willing to answer questions. The agents then questioned him about the firearms transactions that led to his arrest and also asked him whether he had ever shot anyone, to which he answered that he had “shot another guy once.” But when asked whether he had shot a man named Walker, he said “no.” On May 26, 1979, Colorado law enforcement officers gave Springwarnings, and he again signed a statement that he understood his rights and was willing to waive them. He then confessed to the Colorado murder and signed a statement to that effect. Upon being charged in a Colorado state court with first-degree murder, Spring moved to suppress both the March 30 and May 26 statements on the ground that his waiver ofrights was invalid. The trial court held that the ATF agents’ failure to inform Spring before the March 30 interview that they would question him about the Colorado murder did not affect the waiver and that therefore the March 30 statement should not be suppressed. But, while ruling that the March 30 statement was inadmissible on other grounds, the court held that the May 26 statement was made freely, voluntarily, and intelligently and should not be suppressed, and hence, admitted it in evidence, and Spring was convicted. The Colorado Court of Appeals reversed, holding that Spring’s waiver of hisrights before the March 30 statement was invalid because he was not informed that he would be questioned about the Colorado murder, and that the State had failed to prove the May 26 statement was not the product of the prior illegal statement. The Colorado Supreme Court affirmed, holding that Spring’s confession to the murder should have been suppressed because it was the illegal “fruit” of the March 30 statement. The State of Colorado petitioned for certiorari review.”




“No. Justice Lewis F. Powell, Jr. delivered the opinion of the 7-2 majority. The Supreme Court held that there was no evidence that Spring was in any way coerced into signing the waiver of his Fifth Amendment rights or that he was prevented from understanding his rights and the consequences of waiving them. The Constitution does not require that the suspect understand every possible nuance of the consequences of waiving his rights, but rather that he understand that whatever he says may be used against him. The Court also held that police silence regarding the topics of an interrogation is not an attempt to trick the suspect and does not affect the validity of the waiver. Because the interrogation on March 30 was not illegal, the May 26 statements cannot be considered “fruit of the poisonous tree.”In his dissent, Justice Thurgood Marshall argued that the state failed to meet the heavy burden to prove that Spring’s waiver was valid and that the scope of the questioning was highly relevant to Spring’s decision. He also argued that the agents’ silence on the extent of their questions was an interrogation technique designed to draw Spring into confessing more than he would have otherwise. Justice William J. Brennan, Jr. joined in the dissent.”

Case Information

Citation: 479 US 564 (1987)
Argued: Dec 9, 1986
Decided: Jan 27, 1987
Granted: May 5, 1986
Case Brief: 1987