In re D.L.H.
2015 IL 117341
Ill.2015Background
- On Aug. 28, 2012 the State filed a juvenile petition charging 9‑year‑old D.L.H., Jr. with first‑degree murder for injuries to 14‑month‑old T.W.; the infant later died of closed head injury.
- A court‑ordered psychological evaluation (Dr. Cuneo) found respondent borderline intellectual functioning (FSIQ ~78), developmental immaturity, impaired memory, depression, and concluded he was unfit to stand trial and unlikely to be restored within one year.
- Detective Sean Adams interviewed respondent at home twice (Aug. 24 and Aug. 26, 2012); videos of both interviews were admitted at a subsequent discharge hearing. Respondent’s father was present at both interviews but was moved away during the second.
- In the first interview respondent denied wrongdoing, explained a prior admission to DCFS was to protect adults, and implicated another child (Dre). Detective Adams gave Miranda warnings (though custodial status was disputed).
- In the second interview Adams used deception, repeated assurances of no consequences, minimized wrongdoing as an “accident,” and explicitly solicited an admission that respondent hit the child “once”; respondent eventually admitted hitting T.W. once.
- Trial court denied suppression of the statements, later found respondent “not not guilty” at a discharge hearing and remanded him for up to the statutory treatment period; the appellate court reversed suppression rulings and remanded. The Illinois Supreme Court affirmed in part, reversed in part, and remanded for harmless‑error review.
Issues
| Issue | State's Argument | Respondent's Argument | Held |
|---|---|---|---|
| Whether the interviews were custodial (Miranda) | Not custodial; questioning at home, single officer, father present, short duration — Miranda not required | Custodial because of respondent's age, vulnerability, and statutory protections for <13; counsel required if custodial | Not custodial under objective Miranda test; Miranda warnings therefore not required |
| Whether statements were voluntary (Fourteenth Amendment/due process) | Statements were voluntary under totality of circumstances; first interview voluntary and second admissible | Given age, intellectual deficits, and coercive tactics (promises, deception) statements were involuntary and must be suppressed | First interview voluntary; second interview involuntary and its inculpatory statements must be suppressed |
| Effect of Juvenile Court Act §5‑170(a) (counsel for <13 during custodial interrogation) | Not reached because no custody; statute inapplicable | Statute mandates counsel during custodial interrogation of minors under 13 and suppression if violated | Court declined to decide §5‑170(a) because it found questioning noncustodial; did not enforce statutory counsel requirement here |
| Harmless‑error and sufficiency of evidence after suppression | Any error admitting second interview statements was harmless given other inculpatory evidence (DCFS and family statements) | Admission was prejudicial; suppression affects sufficiency at discharge hearing | Illinois Supreme Court remanded to appellate court to perform harmless‑error analysis and consider other unresolved claims |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishes procedural warnings for custodial interrogation)
- J.D.B. v. North Carolina, 564 U.S. 261 (child's age is relevant to Miranda custody analysis)
- People v. Braggs, 209 Ill. 2d 492 (sets factors for custody inquiry under Miranda in Illinois)
- People v. Slater, 228 Ill. 2d 137 (discusses custodial factors and voluntariness doctrine)
- Haley v. Ohio, 332 U.S. 596 (special care required when evaluating juvenile confessions)