Brief of Center on Wrongful Convictions of Youth, et al., as Amici Curiae in Support of Petitioner
Center on Wrongful Convictions of Youth, et al.
SummaryOriginal

Summary

Age must be a factor in custody determination because juveniles, particularly those under the age of fifteen, are especially vulnerable to making false confessions and unreliable statements in response to police interrogation tactics.

2010 | Federal Juristiction

Brief of Center on Wrongful Convictions of Youth, et al., as Amici Curiae in Support of Petitioner

Keywords youth; false confessions; youthful suspects; interrogations
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Summary of Argument

The Miranda rule is an important safeguard that was designed to protect against coerced and unreliable statements. Indeed, this Court created the now famous Miranda warnings to counteract the “inherently compelling pressures” that define a police interrogation. Miranda v. Arizona, 384 U.S. 436, 467 (1966). These pressures have proven to be so powerful that they can “induce a frighteningly high percentage of people to crimes they never committed.” Corley v. United States, 129 S. Ct. 1558, 1570 (2009). Recent empirical and social science research only confirm what was stated by this Court forty-three years ago: when it comes to children and young adolescents, there may be even more reasons to “distrust” interrogation-induced confessions. See In re Gault, 387 U.S. 1, 48-52 (1967); see also Steven A. Drizin & Richard A. Leo, The Problem of False Confessions in the Post-DNA World, 82 N.C. L. Rev. 891, 944-45 (2004), cited in Corley, supra (noting that 35 percent of 113 proven false confessions were made by individuals under the age of eighteen).

Where other briefs presented to this Court underscore why age must be a factor in the custody determination of Miranda, Amici submit this brief to emphasize that, if it is not, there will be an increase in uncounseled and potentially unreliable confessions from children. This is especially so in the context of an inschool interrogation, such as the one to which J.D.B. was subject, where children are already restricted in their freedom of movement and ordered to obey authority. See Paul Holland, Schooling Miranda: Police Interrogation in the Twenty-First Century Schoolhouse, 52 Loy. L. Rev. 39, 85-86 (2006). To prevent such miscarriages of justice, the Miranda safeguards must be robust to assure that children understand their rights not to speak to the police.

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Summary of Argument

The Miranda rule safeguards individuals against coerced and unreliable statements during police interrogations. Empirical and social science research has demonstrated that children and adolescents are particularly susceptible to the pressures of interrogation, leading to a higher incidence of false confessions.

The Inherent Pressures of Interrogation

Miranda warnings were established to counteract the "inherently compelling pressures" of police interrogations, which can induce individuals to confess to crimes they did not commit. These pressures are amplified for juveniles, who may be more easily intimidated and influenced by authority figures.

False Confessions among Juveniles

Studies have shown that a significant percentage of proven false confessions involve individuals under the age of eighteen. Children and adolescents may lack the cognitive maturity and experience to fully understand their rights and the consequences of their statements.

Interrogations in School Settings

In-school interrogations pose additional risks for juveniles. The restricted environment and the expectation of obedience to authority can further undermine a child's ability to resist pressure and make informed decisions.

The Importance of Robust Miranda Safeguards

To prevent miscarriages of justice, it is crucial to ensure that children fully comprehend their Miranda rights and the implications of waiving them. Robust safeguards are necessary to protect the reliability and voluntariness of juvenile confessions, especially in the context of in-school interrogations.

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Summary of Argument

The Miranda rule protects individuals from making coerced or unreliable statements during police interrogations. It requires police to inform suspects of their rights, including the right to remain silent and the right to an attorney.

The Impact of Interrogations on Children

Interrogations can be particularly intimidating for children and young adolescents, who may be more likely to make false confessions. This is because they are more susceptible to pressure and may not fully understand their rights.

The Importance of Miranda Safeguards for Children

In school settings, where children are already under authority and have limited freedom of movement, it is crucial to ensure that they understand their Miranda rights. Without these safeguards, there is an increased risk of uncounseled and potentially unreliable confessions.

Conclusion

To prevent miscarriages of justice, it is essential to apply the Miranda safeguards robustly to protect children's rights during police interrogations. This is especially important in school settings, where children may be particularly vulnerable to coercion.

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Summary of Argument

The Miranda rule is a rule that protects people from being forced to say things that could get them in trouble. When you're arrested, the police have to tell you about your rights, like the right to stay silent and the right to have a lawyer. This is called the Miranda warning.

Why is it Important for Kids?

Kids are especially vulnerable to making false confessions. They may not understand their rights or the consequences of talking to the police. They may also be scared or pressured by adults.

In-School Interrogations

When kids are questioned by police at school, it's even more important to make sure they understand their rights. Kids are used to following orders from teachers and other adults, so they may feel like they have to talk to the police even if they don't want to.

The Bottom Line

The Miranda rule is there to protect kids from making false confessions that could ruin their lives. It's important to make sure that kids know their rights and that they feel comfortable talking to a lawyer before they talk to the police.

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Summary of Argument

When police question someone, they have to follow a special rule called the Miranda rule. This rule says that police have to tell people they have the right to stay silent and have a lawyer present.

Why is this important? Because when police question people, they can feel a lot of pressure to say what the police want to hear. This can be especially true for kids.

Kids are more likely to say things that aren't true when they're being questioned by police. This is because they might be scared or confused. They might also feel like they have to obey the police because they're in charge.

That's why it's so important for kids to know their rights. If a police officer ever questions you, remember that you have the right to stay silent and ask for a lawyer. This will help make sure that you don't say anything that could get you in trouble.

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Footnotes and Citation

Cite

Brief of Center on Wrongful Convictions of Youth, et al., as Amici Curiae in Support of Petitioner, J.D.B. v. State of North Carolina, No. 09-11121 (U.S. Dec. 26, 2010).

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