A.M.C. v. STATE, 2021 OK CR 20

Appellant A.M.C., age 17, was arrested Aug. 10, 2020 on an outstanding probation-warrant after being identified by homicide detectives as present at an Aug. 7 murder scene.
Detectives read Miranda warnings from a printed form; A.M.C. initialed each right and signed the waiver. The recorded custodial interview lasted under 60 minutes and occurred without a parent, guardian, adult representative, or attorney present.
During the interview A.M.C. denied the killing but admitted possessing and firing a gun; he was later booked on a first‑degree murder probable‑cause affidavit but ultimately charged with Possession of a Firearm After Juvenile Adjudication.
A.M.C. moved to suppress his statement under 10A O.S. § 2-2-301(A) (juvenile custodial interrogation protections), sought a competency evaluation, and demurred for insufficiency of the evidence; the trial court denied relief and a jury adjudicated him delinquent.
On appeal A.M.C. raised three issues: (1) statutory/interrogation admissibility under § 2-2-301(A); (2) denial of a competency evaluation; and (3) denial of his demurrer for insufficient evidence.

Issue	Appellant's Argument	State's Argument	Held
Admissibility of confession under 10A §2-2-301(A) (juvenile interrogation)	§2-2-301 required presence of a parent/attorney because A.M.C. was a child when interrogated	§2-5-205(B) and the homicide investigation mean a 17‑year‑old suspected of first‑degree murder is treated as an adult for interrogation; Miranda/voluntariness govern	Court affirmed: treating a 17‑year‑old questioned about first‑degree murder as governed by Miranda (not §2-2-301) was proper; confession admissible
Competency evaluation	Requested new competency exam; trial judge erred by denying it	Prior 2019 competency finding and no new facts justified re-evaluation	Court affirmed: no abuse of discretion; prior competency findings and judge’s conclusions supported denial
Sufficiency of evidence / demurrer	Only proof of possession was the confession (which should be suppressed) so evidence insufficient	Confession was admissible and circumstantial evidence corroborated it	Court affirmed: evidence sufficient; demurrer properly overruled

Neloms v. State, 274 P.3d 161 (Okla. Crim. App. 2012) (abuse‑of‑discretion standard for appellate review of trial rulings)
Taylor v. State, 419 P.3d 265 (Okla. Crim. App. 2018) (discussion on timing of Sixth Amendment counsel attachment and juvenile charging implications)
Newman v. State, 466 P.3d 574 (Okla. Crim. App. 2020) (standard for reviewing sufficiency of the evidence)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (defines custodial interrogation and Miranda warning/waiver requirements)