In re S.D.
SummaryOriginal

Summary

Vermont Supreme Court allows juvenile's statements in delinquency case; Miranda warnings not required.

2022 | State Juristiction

In re S.D.

Keywords juvenile delinquency ; juvenile justice; juvenile rights; subject-matter jurisdiction; Miranda warnings; delinquency proceeding; custody during questioning

Abstract

In re S.D. involved a Vermont juvenile (S.D.) who challenged the admissibility of statements made during questioning by law enforcement. S.D. argued he was in custody and should have received Miranda warnings. The Vermont Supreme Court disagreed. They distinguished between "delinquency proceedings" and criminal prosecutions, finding Miranda warnings weren't required in this non-felony context. The court determined whether a reasonable juvenile felt free to leave mattered more than the location of questioning.

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Abstract

In re S.D. involved a Vermont juvenile (S.D.) who challenged the admissibility of statements made during questioning by law enforcement. S.D. argued he was in custody and should have received Miranda warnings. The Vermont Supreme Court disagreed. They distinguished between "delinquency proceedings" and criminal prosecutions, finding Miranda warnings weren't required in this non-felony context. The court determined whether a reasonable juvenile felt free to leave mattered more than the location of questioning.

The case In re S.D. involved a juvenile from Vermont (S.D.) who contested the use of statements he made during an interrogation by law enforcement. S.D. asserted that he was in custody and should have been given Miranda warnings. The Vermont Supreme Court disagreed with S.D.'s claim. The court differentiated between proceedings for delinquency and criminal prosecutions, concluding that Miranda warnings were not required in cases that did not involve a felony. The court determined that the key factor was whether a reasonable juvenile would feel free to leave the situation, not just the location where the questioning occurred.

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Abstract

In re S.D. involved a Vermont juvenile (S.D.) who challenged the admissibility of statements made during questioning by law enforcement. S.D. argued he was in custody and should have received Miranda warnings. The Vermont Supreme Court disagreed. They distinguished between "delinquency proceedings" and criminal prosecutions, finding Miranda warnings weren't required in this non-felony context. The court determined whether a reasonable juvenile felt free to leave mattered more than the location of questioning.

The case In re S.D. involved a legal dispute concerning the admissibility of statements made by a juvenile (S.D.) during questioning by law enforcement officers in Vermont. S.D. argued that he was in custody at the time of the questioning and therefore should have been given Miranda warnings, a legal requirement informing individuals of their rights against self-incrimination.

The Vermont Supreme Court ruled against S.D., distinguishing between juvenile delinquency proceedings and criminal prosecutions. The court held that Miranda warnings are not required in non-felony juvenile delinquency proceedings. Instead of focusing solely on the location of the questioning, the court emphasized the subjective test of whether a reasonable juvenile would have felt free to leave the questioning. This decision suggests that the focus in juvenile delinquency proceedings should be on the individual's perceived freedom to leave, rather than simply the physical setting of the questioning.

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Abstract

In re S.D. involved a Vermont juvenile (S.D.) who challenged the admissibility of statements made during questioning by law enforcement. S.D. argued he was in custody and should have received Miranda warnings. The Vermont Supreme Court disagreed. They distinguished between "delinquency proceedings" and criminal prosecutions, finding Miranda warnings weren't required in this non-felony context. The court determined whether a reasonable juvenile felt free to leave mattered more than the location of questioning.

The case of In re S.D. involved a young person in Vermont (S.D.) who questioned whether the things he said to police could be used against him in court. S.D. claimed he felt like he couldn't leave the police station, which meant he should have been given his Miranda rights. The Vermont Supreme Court decided that S.D. was wrong.

The court determined that police don't always have to give Miranda warnings in cases where the minor is not being charged with a serious crime. The court focused on whether a young person would feel free to leave, instead of where the questioning happened. This means that even if the questioning takes place at a police station, it doesn't automatically mean that the child is in custody and needs Miranda warnings.

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Abstract

In re S.D. involved a Vermont juvenile (S.D.) who challenged the admissibility of statements made during questioning by law enforcement. S.D. argued he was in custody and should have received Miranda warnings. The Vermont Supreme Court disagreed. They distinguished between "delinquency proceedings" and criminal prosecutions, finding Miranda warnings weren't required in this non-felony context. The court determined whether a reasonable juvenile felt free to leave mattered more than the location of questioning.

The case of In re S.D. was about a young person in Vermont (named S.D.), who thought the things he said to police during questioning shouldn't be used against him in court.

When being questioned, S.D. said he felt like he couldn't leave the police station, which meant he should have been given his Miranda rights. Because the police didn't give him Miranda warnings, he argued that what he said couldn't be used in court.

The Vermont Supreme Court decided that S.D. was wrong. The court said that police don't always have to give Miranda warnings in cases where the minor is not being charged with a serious crime. The court focused on whether a young person would feel free to leave, instead of where the questioning happened. This means that even if the questioning takes place at a police station, it doesn't automatically mean that the minor is in custody and needs Miranda warnings.

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Footnotes and Citation

Cite

In re S.D., 2022 VT 44 (Vt. 2022)

Highlights