In re D.G.
2017 UT 79
| Utah | 2017Background
- Two 14–15-year-old boys (D.G. and R.G.) were accused of aggravated sexual assault; victim later reported the offenses to West Valley City Police.
- A detective interviewed each boy separately at school in the school resource officer’s office; neither parent or attorney was present; each was given Miranda warnings and then spoke to the detective and made inculpatory statements.
- Both juveniles moved to suppress their post-Miranda statements, arguing the waivers were not knowing and voluntary; the juvenile court held an evidentiary hearing (mothers and detective testified) and denied suppression.
- After a bench trial, both were adjudicated delinquent; they appealed the suppression ruling to the Court of Appeals, which certified the case to the Utah Supreme Court.
- The Utah Supreme Court reviewed whether, under the totality of the circumstances and Rule 27A, the juveniles knowingly, intelligently, and voluntarily waived Miranda rights during school interviews.
Issues
| Issue | Appellants' Argument | State's Argument | Held |
|---|---|---|---|
| Were D.G. and R.G.’s post-Miranda statements admissible because they validly waived Miranda? | Waivers invalid: juveniles lacked capacity, no parent present, warnings delivered in rehearsed/brief form at school. | Waivers valid: both minors were 14+, understood warnings, no coercion, detective checked comprehension, totality supports voluntariness. | Waiver valid; juvenile court did not err—totality shows knowing, intelligent, voluntary waivers. |
| Does the absence of a parent/guardian render a waiver invalid per Rule 27A? | Parent absence undermines voluntariness; Rule 27A presumption unconstitutional (argued). | Rule 27A presumes minors 14+ capable; lack of parent is a factor but not dispositive. | Lack of parent was a factor but not determinative; juveniles did not rebut Rule 27A presumption. |
| Were the detective’s Miranda recitations and methods sufficient? | Warnings were scripted, quickly delivered, with limited pausing for comprehension—insufficient for juveniles. | Warnings satisfied constitutional requirements; detective asked follow-up questions confirming understanding. | Although not best practices, the recitation and follow-up were sufficient under the totality test. |
| Should school-setting custody/call-for-best-practices change the analysis? | School setting constrains freedom and parents should be notified/present; custody analysis differs in schools. | Constitution requires totality test; best practices are not constitutionally mandated. | Court declined a per se rule for school settings; noted best practices but applied traditional totality analysis. |
Key Cases Cited
- State v. Bybee, 1 P.3d 1087 (Utah 2000) (establishes totality-of-circumstances factors for juvenile Miranda waivers)
- Fare v. Michael C., 442 U.S. 707 (1979) (adopts totality-of-circumstances for juvenile Miranda waiver validity)
- Haley v. Ohio, 332 U.S. 596 (1948) (recognizes special susceptibility of minors in custodial interrogation)
- J.D.B. v. North Carolina, 564 U.S. 261 (2011) (considers age in custody analysis)
- In re Gault, 387 U.S. 1 (1967) (recognizes the need for special caution with juvenile admissions and due process protections)
- State v. Dutchie, 969 P.2d 422 (Utah 1998) (state bears burden to prove valid Miranda waiver)