State Of Washington v. J.w., Dob: 7/22/97, 72967-5

J.W., a minor, was seated with two other young women outside a Safeway when officers investigated suspected shoplifting; officers observed a bag with alcohol near J.W.
Officer Shone first obtained names/IDs; Officer Hurley repeated J.W.’s DOB/age and warned she could be arrested for minor possession of alcohol.
J.W. asked to step aside with Officer Hurley; a few feet away she confessed to stealing the alcohol.
Officers waited 15–20 minutes for another officer to return; after the other officer arrived J.W. was arrested and given a CrR 3.1 warning (not a full Miranda warning).
J.W. moved to suppress her statements; the trial court found she was in custody but there was no interrogation and admitted the confession; on appeal the court reviewed custody de novo and considered harmless error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether J.W. was in custody for Miranda purposes when she confessed	J.W.: her age, the officer’s arrest-warning, and her detention length made the encounter custodial	State: the encounter was a brief investigatory (Terry) stop, not custodial	Not custodial — the stop was a Terry investigatory detention; confession admissible
Whether officers’ statement amounted to interrogation (Miranda functional equivalent)	J.W.: Hurley’s remark was the functional equivalent of interrogation intended to elicit an admission	State: no interrogation occurred; but custody is dispositive	Court did not decide because custody resolved Miranda claim (J.W. was not in custody)
If admission was erroneous, whether error was harmless beyond a reasonable doubt	J.W.: admission of confession prejudiced the adjudication	State: untainted evidence (video, manager, officers’ observations) overwhelmingly proved theft	Any error was harmless — untainted evidence independently supported the same outcome
Sufficiency of appellant’s other assignments of error (two factual-findings challenges)	J.W.: trial court erred in specific factual findings about who initiated the post-warning conversation	State: no substantive response on appeal	Abandoned/waived for failing to brief; court declined to consider further

Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires advisement of rights)
Terry v. Ohio, 392 U.S. 1 (1968) (brief investigatory stops are seizures but typically not Miranda custody)
J.D.B. v. North Carolina, 131 S. Ct. 2394 (2011) (juvenile age is a factor in custody analysis when known or objectively apparent)
Howes v. Fields, 132 S. Ct. 1181 (2012) (custody inquiry is objective; routine detentions may not be custodial)
State v. Heritage, 152 Wn.2d 210 (2004) (routine juvenile encounters analogous to Terry stops are not necessarily custodial)
State v. Walton, 67 Wn. App. 127 (1992) (Terry-stop questioning of juveniles about alcohol was noncustodial)