Confessions made by juveniles in criminal matters cannot be taken at face value. Extreme care must be taken to evaluate the nature of the confession and whether it was made knowingly and voluntarily. This issue was at the heart of In re D.F., 2015-Ohio-2922 in which the defendant appealed a decision handed down by the Franklin County Court of Common Pleas, Division of Domestic Relations, Juvenile Branch.
A kid was walking down the street in Columbus, Ohio when he was jumped by a group of teenagers. They beat him up and asked for his possessions. Instead of complying, the kid ran to a nearby gas station where he got the attention of a city police officer.
Later that day, Columbus police detained a teenager that fit the description of one of the assailants – the defendant-appellant. Two complaints were filed against the defendant in connection with the incident, charging the 13-year-old with delinquency arising out of second degree robbery, third degree robbery, kidnapping, aggravated riot, and felonious assault.
The defendant filed a motion to suppress his confession, the judge denied the motion, and the defendant objected to the judge’s denial. The defendant’s objection was overruled, and the court found that the teenager was guilty of the charges against him.
On appeal, the defendant claimed that the lower court was in error to deny him a motion to suppress his confession, based on protections granted in the fifth and Fourteenth Amendments to the U.S. Constitution, as well as the corresponding Article 1, Section 10 of the Ohio Constitution. According to the defendant, he did not knowingly or voluntarily give up his Miranda rights.
The state attempted to contest the defendant-appellant’s appeal, claiming that if the defendant disagreed, he should have not only objected to the judge’s initial denial of the motion to suppress, but also the final judgment.
In response, the appeals court said that the state’s claim had no merit. Citing State v. French, the appeals court explained that it is unnecessary for a defendant to renew an objection once a decision regarding a motion to suppress has been entered.
A Look at the 5th and 14th Amendments
The defendant-appellant appealed on the grounds that the juvenile court judge erroneously denied his motion to suppress confession, based on protections found in the Fifth and Fourteenth Amendments to the U.S. Constitution. The Fifth Amendment offers the protection of freedom from self-incrimination, which applies equally to juveniles as it does to adults.
In cases involving juvenile offenders, extreme caution must be taken to ensure that testimony is obtained voluntarily and not arising out of coercion or confusion. The defendant-appellant in this case may have waived his Miranda rights to give a confession, but courts still have to consider whether confessions from juveniles are truly made voluntarily and with understanding.
When a court is considering a defendant’s confession, they cannot look at the confession in isolation, but rather they must consider the circumstances. For example, were any coercive or deceptive police tactics used to obtain the confession? Were the defendant’s parents present at the time of the confession? What was the defendant’s mental/physical state at the time of the interrogation?
If your juvenile son or daughter has been accused of a crime, we invite you to contact Koffel Brininger Nesbitt in Columbus, Ohio today to ensure their rights are protected.