Background

• Jesse Pearson, 17, robbed an elderly man in Waterloo and was later apprehended with Weiss’s blood on his shirt.
• Pearson invoked Miranda rights at the Waterloo police station and refused to talk until returning to Bremwood and consulting his attorney.
• Pearson was placed in Trinity Cottage at Bremwood, a non-lockdown youth home, for status assessment by his caseworker, Marie Mahler.
• Mahler interviewed Pearson July 15 as part of juvenile proceedings, and Pearson confessed to hitting Weiss after being asked if he did what authorities said.
• The district court denied suppression; the court of appeals affirmed admission of the July 15 confession but reversed on going-armed due to a marshaling instruction error.
• The Iowa Supreme Court held the July 15 interview was not custodial under Miranda, making the confession admissible, and affirmed robbery and willful-injury convictions while remanding the going-armed charge for a new trial with a corrected instruction.

Issues

Key Cases Cited

• Miranda v. Arizona, 384 U.S. 436 (1966) (required warnings before custodial interrogation)
• Edwards v. Arizona, 451 U.S. 477 (1981) (custodial interrogation after invocation requires counsel)
• J.D.B. v. North Carolina, 564 U.S. _ (2011) (age informs custody determination for Miranda)
• Maryland v. Shatzer, 559 U.S. _ (2010) (custody analysis and force of Miranda in repeated interrogations)
• Minnesota v. Murphy, 465 U.S. 420 (1984) (familiar probation context not custodial if not coercive)
• State v. Deases, 518 N.W.2d 784 (Iowa 1994) (factors for determining custody in Iowa)
• State v. Taylor, 596 N.W.2d 55 (Iowa 1999) (movement element in going-armed with intent)
• State v. Ray, 516 N.W.2d 863 (Iowa 1994) (movement as element of going armed)