In re R.C., 153 N.E.3d 538

Appellant R.C., a 17‑year‑old, was charged in juvenile court with gross sexual imposition (O.R.C. 2907.05(A)(4)) for allegedly touching 10‑year‑old M.G.’s buttocks (and an earlier incidental breast touch) while children were in R.C.’s bedroom.
M.G. testified at adjudication that R.C. put his hand down her pants on the top bunk; she reported the matter about a month later and marked a body drawing.
Multiple witnesses in the room (friends, R.C.’s brother and father) did not observe the buttocks contact; some testimony about positions/timing conflicted.
Two months after the alleged incident Detective Engle interviewed R.C. in an unlocked, unmarked patrol vehicle in R.C.’s driveway with R.C.’s mother present; the ~30‑minute audio shows leading questions and R.C. giving “I don’t remember,” “sort of,” and “I think so” responses.
R.C. moved to suppress his statements, arguing Miranda warnings were inadequate and any confession was involuntary; the trial court denied suppression, adjudicated R.C. delinquent, and R.C. appealed arguing suppression error and that the adjudication was against the manifest weight of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (R.C.)	Held
1) Was the interview custodial requiring Miranda warnings?	Interview was noncustodial (mother present, told he was free to leave, unlocked car at home).	Interview was custodial; Miranda warnings incomplete and waiver invalid.	Not custodial; Miranda not triggered; trial court properly denied suppression on that ground.
2) Were R.C.’s statements voluntary under the Due Process/totality test?	Statements were voluntary; no coercive police tactics; mother present; brief noncoercive interview.	Statements involuntary due to age, memory/I.E.P., suggestibility, and highly leading questions supplying details.	Statements voluntary under totality of circumstances; no coercive conduct that overbore will; suppression properly denied.
3) Was the adjudication for gross sexual imposition against the manifest weight of the evidence?	Victim’s in‑court testimony credible and corroborated by R.C.’s recorded admissions (qualified). The buttocks contact supports inference of sexual purpose.	Evidence inconsistent; recorded interview was the product of suggestion and should be given minimal weight; state failed to prove sexual purpose beyond reasonable doubt.	Not against the manifest weight. Court credited victim and inferred sexual arousal/gratification from placement of R.C.’s hand inside victim’s pants.

Miranda v. Arizona, 384 U.S. 436 (1966) (Miranda warnings required for custodial interrogation).
J.D.B. v. North Carolina, 564 U.S. 261 (2011) (a suspect's age may be considered in the custody analysis if known or objectively apparent).
State v. Barker, 149 Ohio St.3d 1 (2016) (apply totality‑of‑circumstances to juvenile confessions; consider age, experience, capacity).
State v. Burnside, 100 Ohio St.3d 152 (2003) (trial court is factfinder at suppression hearings; appellate courts accept factual findings supported by credible evidence).
State v. Codeluppi, 139 Ohio St.3d 165 (2014) (mixed question of law and fact review for suppression rulings).
Thompson v. Keohane, 516 U.S. 99 (1995) (custody is an objective inquiry based on circumstances of questioning).
Dickerson v. United States, 530 U.S. 428 (2000) (voluntariness of confession measured by totality of the circumstances).
Lego v. Twomey, 404 U.S. 477 (1972) (state must prove voluntariness of confession by preponderance).