Summary
The Pennsylvania Supreme Court held that school police officers who were judicially appointed and authorized to exercise municipal police powers are law enforcement officers for purposes of Miranda. Because the juvenile was detained and questioned without receiving Miranda warnings, the court held that his Fifth Amendment rights were violated, reversed the Superior Court, and remanded the matter.
Holdings
- School police officers who are judicially appointed and expressly authorized to exercise the same powers as municipal police on school property are law-enforcement officers within the meaning of Miranda.
- Because R.H. was subjected to custodial interrogation by law-enforcement officers without Miranda warnings, his Fifth Amendment privilege against self-incrimination was violated and the confession could not be used against him.
Questions Presented
- Whether school police officers who are judicially appointed and authorized to exercise the same powers as municipal police are law-enforcement officers for purposes of Miranda.
- Whether a juvenile's confession obtained during custodial interrogation by such a school police officer without Miranda warnings must be suppressed.
Disposition
reversed_and_remanded
Cases Cited (10)
- Commonwealth v. Hall, 549 Pa. 269, 701 A.2d 190, 197 (1997)(followed)
- Commonwealth v. Cortez, 507 Pa. 529, 491 A.2d 111, 112 (1985)(followed)
- Thompson v. Keohane, 516 U.S. 99, 107 (1995)(followed)
- Miranda v. Arizona, 384 U.S. 436, 444, 478-79 (1966)(followed)
- In re Gault, 387 U.S. 1, 57 (1967)(followed)
- Commonwealth v. Chacho, 500 Pa. 571, 459 A.2d 311, 314-15 (1983)(followed)
- Commonwealth v. Williams, 539 Pa. 61, 650 A.2d 420, 427 (1994)(followed)
- Commonwealth v. Cass, 551 Pa. 25, 709 A.2d 350 (1998)(distinguished)
- In the Interest of F.B., 555 Pa. 661, 726 A.2d 361 (1999)(distinguished)
- Gondelman v. Commonwealth, 520 Pa. 451, 554 A.2d 896, 898 (1989)(followed)
Cited In (0)
No citing cases on record yet.
Court Document
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