## Facts

- John Leroy Spring shot and killed Walker during a Colorado hunting trip in February 1979.
- Federal agents arrested Spring on March 30, 1979, during an undercover investigation of interstate transportation of stolen firearms.
- After receiving Miranda warnings, Spring signed a written waiver and answered questions about firearms; agents then asked whether he had ever shot anyone, and he admitted shooting “another guy once” but denied shooting Walker.
- On May 26, 1979, Colorado officers again gave Miranda warnings; Spring signed another written waiver, confessed to Walker’s murder, and signed a written statement.
- Spring was charged in Colorado state court with first-degree murder.

## Issues

1. Whether a Miranda waiver is invalid when the suspect is not informed before questioning of all crimes or topics about which officers may interrogate him.
2. Whether Spring’s May 26 murder confession was inadmissible as “fruit of the poisonous tree” due to the March 30 interrogation.

## Decision

- The Supreme Court reversed the Colorado Supreme Court (7–2).
- A suspect’s awareness of all potential subjects of questioning is not relevant to whether a Miranda waiver is knowing, intelligent, and voluntary.
- Because the March 30 Miranda waiver was valid, that interrogation was not constitutionally unlawful.
- The May 26 confession was not suppressible as derivative evidence because there was no prior constitutional violation to taint it.

## Legal Principles

- Miranda does not require police to inform a suspect in advance of every subject or crime that may be discussed during interrogation.
- The validity of a Miranda waiver turns on whether the suspect understood and voluntarily relinquished the rights to remain silent and to counsel, assessed under the totality of the circumstances.
- Absent official coercion or deception that undermines understanding of the rights themselves, nondisclosure of interrogation topics does not vitiate a waiver.
- Evidence cannot be excluded as “fruit of the poisonous tree” unless there is an underlying constitutional violation.

## Conclusion

The Court held that Spring’s Miranda waivers were valid despite lack of advance notice that questioning would include a homicide, and it allowed admission of his later murder confession because the earlier interrogation was not constitutionally tainted.


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