In the Interest of: N.B., a Minor, Appeal of Comm., In the Interest of: N.B., a Minor, Appeal of Comm. No. 527 WDA 2016

Mother learned her 14-year-old twin sons had sexual contact with a 9-year-old neighbor and reported it to the school; police were asked to interview the boys.
Lieutenant Caskey requested the boys be brought to the police station; Mother voluntarily brought them and was told she could be present for interviews.
Officer Caskey read Miranda warnings to Mother and both boys, informed them the interview was audio/visually recorded, and interviewed each boy separately; no written waivers were signed.
Appellee (N.B.) was interviewed first for about ten minutes individually (27 minutes total interview session) in a calm setting with an unlocked door; he made detailed admissions and agreed to further interviews.
At the suppression hearing, Appellee testified he had limited understanding, felt forced by his mother to confess, and lacked appreciation of Miranda rights; Mother testified she understood the warnings and told him to tell the truth.
The juvenile court suppressed Appellee’s statements, finding he was compelled by his mother; the Commonwealth appealed and the Superior Court reversed and remanded.

Issue	Commonwealth's Argument	Appellee's Argument	Held
Whether Appellee’s confession was voluntary under the totality of circumstances	Confession was voluntary: Mother voluntarily brought him, Miranda warnings were given and understood, interview was brief and noncoercive	Confession involuntary: Appellee lacked true understanding, felt compelled by his mother to confess	Superior Court: Confession was voluntary; juvenile court erred in suppressing statements

Commonwealth v. Williams, 475 A.2d 1283 (Pa. 1984) (adopts totality-of-circumstances test for juvenile waivers and notes presence of an interested adult is a relevant factor)
In re T.P., 78 A.3d 1166 (Pa. Super. 2013) (standard of review on suppression appeals; consider juvenile evidence favorably)
In re V.C., 66 A.3d 341 (Pa. Super. 2013) (lists factors for voluntariness: duration, physical/psychological state, detention conditions, interrogator attitude)
In re N.M., 141 A.3d 539 (Pa. Super. 2016) (clarifies interested-adult presence is a factor, not per se requirement)
Commonwealth v. Wright, 14 A.3d 798 (Pa. 2011) (focuses voluntariness inquiry on coercion by law enforcement)
Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda-warning requirements)