Summary
The Utah Supreme Court considers whether two fifteen-year-old juveniles knowingly, intelligently, and voluntarily waived their Miranda rights during police interviews conducted at school without a parent present. Applying the totality-of-the-circumstances test and Utah Rule of Juvenile Procedure 27A, the court holds that the waivers were valid and affirms the denial of the motions to suppress their post-Miranda statements. The court does not reach the juveniles’ constitutional challenge to Rule 27A’s presumption because the issue was not preserved.
Topics
Practice areas
Questions Presented
- Whether the Miranda warnings given to D.G. and R.G. during their school interviews were legally sufficient.
- Whether D.G. and R.G. knowingly, intelligently, and voluntarily waived their Miranda rights under the totality of the circumstances.
- Whether the juvenile court erred in denying the motions to suppress the post-Miranda statements.
Holdings
- The Miranda warnings given to D.G. and R.G. were sufficient under the standards established by the United States Supreme Court and Utah precedent.
- Both D.G. and R.G. knowingly, intelligently, and voluntarily waived their Miranda rights during their interviews with the detective.
- The juvenile court did not err in denying D.G.'s and R.G.'s motions to suppress their post-Miranda statements.
Key quotations
“And, considering the totality of the circumstances surrounding their waivers, we hold that D.G. and R.G. knowingly and voluntarily waived their Miranda rights during the interview with the detective at their school.” (¶ 2)
“The constitution only mandates that the juvenile knowingly, intelligently, and voluntarily waive his Miranda rights given the totality of the circumstances.” (¶ 40)
Factual background
D.G. and R.G., both fifteen-year-old students, were interviewed separately by a police detective in a school resource officer's office concerning an alleged aggravated sexual assault. Neither had a parent, guardian, or attorney present, but each was advised of Miranda rights, affirmed that he understood them, agreed to speak, and eventually made incriminating statements. The juvenile court found the waivers valid, admitted the statements, and adjudicated both juveniles delinquent.
Procedural history
The State filed a juvenile-court petition alleging aggravated sexual assault against D.G. and R.G. After an evidentiary hearing, the juvenile court denied their motions to suppress statements made during separate school interviews without a parent present. Following a bench trial, the juvenile court adjudicated both juveniles delinquent. They timely appealed, and the court of appeals certified the case to the Utah Supreme Court.