In re T.F., A144085

Background

In May 2014 the Contra Costa County DA amended a juvenile wardship petition to add a felony charge under Penal Code §288(a) alleging that then-13/14-year-old T.F. touched a 3–4-year-old girl, E.C.; the petition followed an earlier and dismissed weapons-on-school-grounds allegation.
Multiple family witnesses (siblings and the child’s mother) reported incidents and disclosures; a 2014 recorded interview of the victim was admitted showing she signaled her vaginal area when asked.
On May 20, 2014, two detectives questioned 15‑year‑old T.F. at school for ~60 minutes without Miranda warnings; he was distraught, repeatedly denied wrongdoing, was arrested, then taken to the station.
At the station a detective read a rapid Miranda warning and shortly thereafter resumed accusatory questioning for ~45 minutes; T.F. ultimately admitted touching the child’s vagina "a little bit over her pants."
The juvenile court suppressed the pre‑Miranda school statements but admitted the post‑Miranda station statements, found the §288(a) allegation true, declared T.F. a ward, and placed him on probation.
The Court of Appeal reversed, holding (1) T.F. did not knowingly, intelligently, and voluntarily waive Miranda rights, (2) the confession was involuntary under due process given his age, limited sophistication, special‑education background, emotional state, and coercive interrogation tactics, and (3) the error was not harmless because, absent the confession, insufficient evidence established sexual intent and that T.F. appreciated wrongfulness under Pen. Code §26.

Issues

Issue	Plaintiff's Argument (People)	Defendant's Argument (T.F.)	Held
Whether T.F. validly waived Miranda rights at the station	The detective gave full Miranda warnings and T.F. indicated understanding (implied waiver); admission was voluntary	Waiver was not knowing/voluntary: warnings were cursory, delivered midstream after a coercive school interrogation, and T.F. was upset, young, and cognitively limited	Waiver invalid: totality shows T.F. did not knowingly, intelligently, and voluntarily waive Miranda rights
Whether the station confession was voluntary under due process	Confession was the product of the interview, not coerced; police tactics were lawful interrogation	Confession was involuntary: prolonged accusatory interrogation, maximization/minimization, deceptive ploys, and T.F.’s youth and disability overbore his will	Confession involuntary under the Fourteenth Amendment given coercive tactics plus juvenile vulnerabilities
Whether admission of the confession was harmless error	Sufficient independent evidence (witness testimony, victim statements) supported guilt without confession	Without the confession there is insufficient evidence of sexual intent and knowledge of wrongfulness required by §288(a) and §26	Error not harmless: confession was critical to proving intent and rebutting §26 presumption, so conviction cannot stand
Proper disposition/remedy	Admission of station statement permissible; affirm judgment	Reverse and remand / reverse judgment and vacate wardship given constitutional error	Judgment reversed (petition not sustained); juvenile disposition vacated

Key Cases Cited

Miranda v. Arizona, 384 U.S. 436 (warning required and waiver must be voluntary)
Oregon v. Elstad, 470 U.S. 298 (midstream warnings may not cure earlier unwarned custodial interrogation in all circumstances)
Fare v. Michael C., 442 U.S. 707 (juvenile waiver requires careful assessment of age, experience, education, intelligence)
In re Gault, 387 U.S. 1 (heightened protections for juveniles in custodial settings)
J.D.B. v. North Carolina, 564 U.S. 261 (child's age is relevant to custody analysis)
Corley v. United States, 556 U.S. 303 (false‑confession risks from custodial pressures)
In re Elias V., 237 Cal.App.4th 568 (danger of maximization/minimization and false confessions in juvenile interrogations)
People v. Whitson, 17 Cal.4th 229 (prosecution burden to prove voluntariness of Miranda waiver)