People v. Patterson
2014 IL 115102
| Ill. | 2015Background
- Defendant Ronald Patterson was 15 when charged with three counts of aggravated criminal sexual assault; his case was automatically transferred from juvenile to adult criminal court under 705 ILCS 405/5-130.
- Patterson confessed after a station-house interview; police assigned a youth officer (Detective Kaminski) who testified he read Miranda warnings, attempted to contact the facility director and DCFS caseworker, and was present (but did not lead) during questioning.
- Trial court denied Patterson’s motion to suppress the statement, found the youth officer credible, and admitted the confession; a jury convicted Patterson on all counts and he received three consecutive 12-year terms (36 years total).
- On appeal the appellate court reversed and ordered a new trial, holding the confession involuntary because (1) no concerned adult had been contacted as required by the Juvenile Court Act and (2) the youth officer improperly participated in the interrogation; it also held certain evidence of the victim’s sexual history should be admissible on remand under a constitutional-necessity theory.
- The Illinois Supreme Court granted review and reversed the appellate court: it held the police made a reasonable attempt to notify a concerned adult, the youth officer did not improperly take an adversarial role, the confession was voluntary under the totality of circumstances, the rape-shield exclusion was not reviewable on the record presented, and the mandatory-transfer statute was constitutional.
Issues
| Issue | People’s Argument | Patterson’s Argument | Held |
|---|---|---|---|
| Whether police complied with 705 ILCS 405/5-405(2) (reasonable attempt to notify a parent/concerned adult) before questioning | Police made a "reasonable attempt"—called the facility director and DCFS caseworker and left messages; director arguably was a person with whom the juvenile resided | Police failed to secure presence/notice of a concerned adult before interrogation; attempt was insufficient and coercive | Reasonable attempt satisfied statutory requirement; appellate court erred to the contrary |
| Whether the youth officer improperly participated in interrogation (so confession involuntary) | Youth officer only stood by, read Miranda warnings, ensured understanding, and did not lead questioning | Youth officer briefly spoke with victim, aided in typing/reading statement, and thereby conflicted with protective role | Youth officer’s conduct did not approach the abandonment found in Murdock; no improper participation requiring suppression |
| Whether confession was involuntary under the totality of circumstances (age, mental capacity, presence of adult, deception, timing) | Confession voluntary: defendant was 15, read and waived Miranda, questioned for ~45 minutes, no coercion or promises, and physical evidence corroborated victim | Coercive atmosphere: no concerned adult present, inadequate attempts to contact one, youth officer’s role, defendant’s alleged limited literacy/special-education status | Confession voluntary after de novo review of totality; trial court’s credibility findings (youth officer, defendant’s understanding) entitled to deference |
| Whether mandatory-transfer statute (705 ILCS 405/5-130) is constitutional (due process, Eighth Amendment, IL proportionate penalties) | Statute is procedural (jurisdictional), not punitive; precedent upholding automatic transfer remains controlling; not within Eighth Amendment protections that produced Roper/Graham/Miller | Automatic transfer is punitive in effect (exposes juveniles to harsher adult sentences) and unconstitutional post-Roper/Graham/Miller because it denies individualized consideration of youth | Upheld statute: due process and Eighth/proportionate-penalties challenges rejected; majority urges legislature to revisit mandatory-transfer scheme though it remains constitutional |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juveniles categorically barred from death penalty; juveniles are constitutionally different from adults)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (life without parole for juveniles convicted of nonhomicide offenses violates the Eighth Amendment)
- Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (mandatory life-without-parole for juveniles unconstitutional; sentencers must consider youth and its characteristics)
- People v. G.O., 191 Ill. 2d 37 (Ill. 2000) (factors for voluntariness of juvenile confessions; totality of circumstances review)
- People v. Morgan, 197 Ill. 2d 404 (Ill. 2001) (upholding juvenile confession where procedural safeguards and totality supported voluntariness)
- People v. Murdock, 2012 IL 112362 (Ill. 2012) (youth officer who actively compiles evidence and leads interrogation cannot serve protective role; standards for juvenile interviews)
- People v. J.S., 103 Ill. 2d 395 (Ill. 1984) (upholding Illinois automatic-transfer statute against due process challenge)
- People v. Miller (Leon Miller), 202 Ill. 2d 328 (Ill. 2002) (addressing proportionality and mandatory life sentences for juveniles; recognizing limited contexts where life is improper)