Summary of Argument

Decades ago, the United States Supreme Court recognized that children must be afforded special consideration during interrogations because they are more vulnerable to the pressures of interrogation than adults. See Haley v. Ohio, 332 U.S. 596, 599 (1948). Since then, Supreme Court jurisprudence has increasingly recognized the significance of adolescent brain development, including in the context of interrogations. See J.D.B. v. North Carolina, 564 U.S. 261, 272-73 (2011); see also Roper v. Simmons, 543 U.S. 551, 569-70 (2005); Graham v. Florida, 560 U.S. 48, 68 (2010); Miller v. Alabama, 567 U.S. 460, 471-72 (2012); Montgomery v. Louisiana, 577 U.S. 190, 206-208 (2016); Jones v. Mississippi, 141 S. Ct. 1307, 1316 (2021).

In denying the motion to suppress Damian’s statements to the police, the trial court failed to recognize that “age is far ‘more than a chronological fact.’” J.D.B., 564 U.S. at 272 (quoting Eddings v. Oklahoma, 455 U.S. 104, 115 (1982)). Damian was 14 years old during the interrogations in April 2018. (Hauschultz’s Br. 10). Upheaval marked Damian’s early years. Damian’s biological parents separated, his mother married Tim Hauschultz, and foster siblings entered their home. (Id. at 8–10). Tim used abuse as discipline—forcing Damian to stand barefoot in the snow, kneel on a paint tray in the driveway, or carry logs for hours in the snow—for minor behaviors. (Id. at 9).

Damian’s brief explains why this Court should find that Damian was in custody during the interrogations and was therefore entitled to Miranda warnings, and why his statements to the police were involuntary. This brief builds on Damian’s brief to emphasize the impacts of Damian’s brain development and trauma on the interrogations.

Summary of Argument

The United States Supreme Court has acknowledged the heightened vulnerability of children during police interrogations (Haley v. Ohio, 1948). Subsequent jurisprudence has emphasized the relevance of adolescent brain development in this context (J.D.B. v. North Carolina, 2011; Roper v. Simmons, 2005; Graham v. Florida, 2010; Miller v. Alabama, 2012; Montgomery v. Louisiana, 2016; Jones v. Mississippi, 2021).

In the case of Damian, a 14-year-old subjected to interrogations in 2018, the trial court overlooked the significance of his age as a factor beyond mere chronology (J.D.B., 2011). Damian's early life was characterized by instability and trauma, including parental separation, remarriage, foster siblings, and physical abuse by his stepfather.

Considering Damian's brain development and trauma history, it is argued that he was effectively in custody during the interrogations, entitling him to Miranda warnings. Furthermore, his statements to the police were involuntary due to the combined effects of his developmental stage and past experiences. This analysis highlights the crucial need for special considerations in police interrogations involving adolescents, particularly those with a history of trauma.

Summary of Argument

The Supreme Court has recognized that children and adolescents are more susceptible to pressure during police interrogations due to their developing brains. This is especially true for children who have experienced trauma.

In the case of Damian, a 14-year-old boy who had experienced significant abuse, the trial court failed to consider the following factors:

• Age: Adolescents' brains are still developing, making them more impulsive and less able to understand the consequences of their actions.

• Trauma: Abuse can have a profound impact on brain development, leading to increased vulnerability to pressure and coercion.

Damian's history of abuse and his young age should have been taken into account when determining whether he was in custody and entitled to Miranda warnings. His statements to the police may have been involuntary due to the combined effects of his age and trauma.

Therefore, it is argued that the trial court's decision to deny the motion to suppress Damian's statements was incorrect and that his statements should be considered inadmissible.

Summary of Argument

A long time ago, the Supreme court in the US said that kids need extra care when being questioned by police because they're not as developed as adults.

Since then, the court has learned more about how teenage brains work. They've realized that teens:

• Are still developing

• Can be easily pressured

• Might not understand their rights

Damian's Story

Damian was only 14 when he was questioned by police. He had a tough childhood: his parents divorced to an abusive stepfather and he had many foster siblings.

Because of his age and his past, Damian should have been treated differently during the questioning. He should have been told his rights and given a chance to have a lawyer present. But that didn't happen.

This brief argues that Damian's statements to the police shouldn't be used against him because:

• He was too young to understand what was happening

• He was scared and pressured

• He didn't have a lawyer to protect his rights

Summary of Argument

A long time ago, the Supreme Court the United States said that kids and teens need to be treated differently when they're being questioned by police. That's because kids and teens are easier to pressure than adults.

Since then, the court has learned more about how kids' brains are still growing. This is especially important when it comes to being questioned by police.

Damian's Story

Damian was 14 years old when he was questioned by police. He had a tough childhood. His parents split up, and his stepfather was abusive. He would make Damian stand in the snow without shoes or carry heavy logs for hours. Because of his age and his difficult past, Damian should have been given special protection during the questioning. He should have been told that he had the right to remain silent and to have a lawyer present. But he wasn't.

As a result, the things Damian said to the police should not be used against him in court.