In re S.B.
2016 Ohio 7732
Ohio Ct. App.2016Background
- Juvenile S.B. was alleged delinquent for rape with a serious-youthful-offender specification; grand jury later indicted the specification.
- Detective Scheurer interviewed 15-year-old S.B., read a Miranda card, and had her sign it; interview lasted ~45–60+ minutes, occurred with the door closed and mother outside.
- S.B. exhibited signs of distress (crying, finger chewing, hood over head), had low tested IQ (composite IQ ~65) and limited academic functioning per school psychologist testimony.
- Detective used a calm, persuasive approach and told S.B. to sign the card to show he had read it; S.B. never asked for counsel or her mother and subsequently was cuffed and detained after the interview.
- The juvenile court granted S.B.’s motion to suppress, finding she did not understand or knowingly waive her rights and that the detective misled her about the waiver.
- The state appealed, arguing S.B. was not in custody and her statements were voluntary; the appellate court affirmed suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether S.B.'s statements were voluntary and admissible | Statements voluntary; not custodial interrogation so Miranda not required | Statements involuntary due to age, low IQ, closed-door interview, misleading waiver; no knowing/intelligent waiver | Affirmed suppression: no affirmative waiver; statements not voluntary |
| Whether S.B. was in custody during the interview | Not in custody; Miranda warnings unnecessary | Functionally custodial (isolated, door closed, detained after), plus vulnerability supports suppression | Court found interrogation custodial in effect and waiver not established |
| Whether S.B. knowingly waived Miranda rights by signing card | Signature on card showed waiver; she did not request counsel | Signature was at detective's direction and merely acknowledged reading, not an informed waiver | No affirmative, knowing, intelligent waiver proven |
| Proper standard for reviewing suppression of juvenile statements | Defer to trial court’s findings of fact; apply law correctly | Totality-of-circumstances must account for juvenile characteristics (age, IQ, demeanor) | Appellate court affirmed under totality-of-circumstances, giving special care to juveniles |
Key Cases Cited
- Ornelas v. U.S., 517 U.S. 690 (U.S. 1996) (reasonable-suspicion and probable-cause determinations reviewed de novo)
- In re C.S., 115 Ohio St.3d 267 (Ohio 2007) (courts should take special care when reviewing juvenile confessions and waivers)
- In re Gault, 387 U.S. 1 (U.S. 1967) (juveniles require protections ensuring admissions are voluntary and not products of ignorance or despair)
- Gallegos v. Colorado, 370 U.S. 49 (U.S. 1962) (juveniles lack full appreciation of police questioning consequences)
- Haley v. Ohio, 332 U.S. 596 (U.S. 1948) (juvenile susceptibility to coercion requires careful scrutiny)
- State v. Fanning, 1 Ohio St.3d 19 (Ohio 1982) (standards for appellate review of factual findings on suppression)