In re R.G.
2017 Utah LEXIS 178
| Utah | 2017Background
- Two 14–15-year-old boys (D.G. and R.G.) were accused of aggravated sexual assault after a classmate reported nonconsensual sexual acts.
- A West Valley City detective interviewed each boy at school in the school resource officer’s office without parents or counsel present; both were read Miranda warnings and each confessed.
- Each moved to suppress the post-Miranda statements, arguing the waivers were not knowing and voluntary; the juvenile court held an evidentiary hearing and denied suppression.
- After a bench trial the juvenile court adjudicated both delinquent and imposed juvenile dispositions; the boys appealed the denial of the suppression motions.
- The Utah Supreme Court reviewed whether, under the totality of the circumstances and Utah Rule of Juvenile Procedure 27A, the juveniles knowingly and voluntarily waived Miranda rights at school.
Issues
| Issue | Plaintiff's Argument (D.G./R.G.) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether juveniles’ post-Miranda statements should be suppressed because the waivers were not knowing and voluntary | Waivers invalid because interviews occurred at school without parents, warnings were scripted/rapid, juveniles are developmentally unable to waive | Warnings were sufficient, detectives asked follow-up questions to confirm comprehension, youths were of age/education to understand, no coercion | Waivers were knowing, intelligent, and voluntary; suppression denied |
| Applicability of Utah R. Juv. P. 27A presumption (14+ presumed capable of waiving without parent) and whether it was rebutted | Rule 27A presumption should apply; appellants argued it’s unconstitutional and that they rebutted it | State relied on the rule and showed minors did not rebut presumption by preponderance | Court did not decide constitutionality of the rule; held appellants failed to rebut presumption and waiver was valid |
| Whether best practices (parent notice/presence, juvenile-friendly warnings, videotape) are required for a valid waiver | Argued best practices should be required for minors to validly waive Miranda | State: best practices are advisable but not constitutionally mandated; totality test controls | Court: best practices recommended but not constitutionally required; totality-of-circumstances governs |
| Whether juvenile-custody analysis differs because interview occurred at school | Argued school setting is coercive and custody analysis should account for it | State noted no coercive tactics shown and court need not alter custody doctrine here | Court declined to resolve broad custody-in-school issue now; did not find coercion here |
Key Cases Cited
- Haley v. Ohio, 332 U.S. 596 (U.S. 1948) (recognizing special vulnerability of minors in custodial settings)
- Fare v. Michael C., 442 U.S. 707 (U.S. 1979) (totality-of-the-circumstances test for juvenile Miranda waivers)
- J.D.B. v. North Carolina, 564 U.S. 261 (U.S. 2011) (custody analysis may consider age of suspect)
- In re Gault, 387 U.S. 1 (U.S. 1967) (juveniles require special caution and protections in adjudicative process)
- State v. Bybee, 1 P.3d 1087 (Utah 2000) (factors for assessing juvenile Miranda waivers under totality test)
- State v. Dutchie, 969 P.2d 422 (Utah 1998) (state bears burden to prove valid Miranda waiver; absence of parent is a factor, not dispositive)