Moore v. State, 30 A.3d 945

Moore was convicted in the Circuit Court for Prince George’s County of first degree felony murder and related offenses, based on an inculpatory statement obtained during a custodial interrogation.
Moore, who was sixteen years old at the time, challenged the confession as involuntary due to police delay and lack of access to his mother.
The circuit court denied the suppression motion; the Court of Special Appeals affirmed, and the case was later granted certiorari by this Court to address voluntariness and the suppression of evidence derived from the statement.
Key factual backdrop includes Moore’s arrest around 1:00 a.m. on March 21, 2007, placement in an interview room around 2:00 a.m., and interrogation beginning after Miranda advisements at approximately 2:00–2:41 a.m., with the now-16-year-old eventually confessing at 8:05 a.m.
A long delay followed before presentation to a District Court Commissioner (roughly twelve and a half hours after arrest), during which multiple officers conducted interrogations and sought warrants, and Moore repeatedly requested to telephone his mother.
The Court of Special Appeals had held that, despite significant unnecessary delay, the confession remained voluntary under the totality of the circumstances.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Moore’s confession voluntary under the totality of the circumstances?	Moore argues the delay and parental-access issues render the confession involuntary.	State contends the confession was voluntary given Moore’s age, rationality, and Miranda compliance.	Yes; the confession was involuntary due to deliberate delay and juvenile factors.
Should the State be prohibited from introducing Moore’s inculpatory statements at trial?	Because the statement is involuntary, it should be suppressed in full.	Voluntariness supports admission of the statement.	Yes; direct and derivative evidence of the inculpatory statement must be excluded at trial.
Did the circuit court err in weighing the delays as a factor in voluntariness?	Delay, especially deliberate and unnecessary delay, weighs heavily against voluntariness.	Delay may be permissible under the circumstances, including administrative needs.	Yes; the delay was weighed heavily against voluntariness and contributed to a finding of involuntariness.
Did Moore’s age and requests to contact his mother meaningfully affect voluntariness?	Juvenile status and parental access are critical factors in assessing voluntariness.	These factors are just part of a broader totality assessment and do not by themselves render a statement involuntary.	Yes; age and denial of parental contact were weighty factors supporting involuntariness.

Jones v. State, 311 Md. 398 (Md. 1988) (juvenile voluntariness factors, including absence of parent)
McIntyre v. State, 309 Md. 607 (Md. 1987) (special caution for juveniles; parental access as a factor)
Williams v. State, 375 Md. 404 (Md. 2003) (prompt presentment and trilogy framework in voluntariness analysis)
Facon v. State, 375 Md. 435 (Md. 2003) (prompt presentment framework; juvenile considerations)
Hiligh v. State, 375 Md. 456 (Md. 2003) (constitutionality of delay and voluntariness factors)
Odum v. State, 156 Md.App. 184 (Md. 2004) (application of delay categories in voluntariness analysis)
Winder v. State, 362 Md. 275 (Md. 2001) (mixed question; de novo constitutional review of voluntariness)
Robinson v. State, 419 Md. 602 (Md. 2011) (guidance on appellate review of voluntariness)