329 Conn. 311
Conn.2018Background
- On March 23, 2012, a group of older teens (including William Castillo, then 16) assaulted middle school students in an attempted robbery; police later identified Castillo as a suspect.
- Detectives visited Castillo’s home on April 10 and again on April 13; on April 13 they interviewed him in the living room with his mother present, using a Spanish-speaking officer as translator.
- Castillo signed a juvenile waiver form and a parental consent form, then gave an oral statement (recorded in writing by a detective) and signed a written statement; the interview lasted about 45–60 minutes; he was not arrested at that time.
- Castillo was later arrested (juvenile warrant) and the case was transferred to the regular criminal docket; he was charged with attempted first- and second-degree robbery, convicted by a jury, and sentenced.
- Castillo moved to suppress the April 13 statements arguing Miranda custodial-interrogation and voluntariness/due process defects; the trial court denied the motion, the Appellate Court affirmed, and the Connecticut Supreme Court granted certification on custody, a factual finding, and whether the Appellate Court should have considered a supervisory-rule request.
Issues
| Issue | Plaintiff's Argument (Castillo) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether Castillo was "in custody" for Miranda purposes during the in-home interrogation | Juvenile status + police conduct created a coercive, police-dominated atmosphere; reasonable juvenile would not feel free to terminate questioning | Interview was noncustodial: occurred in Castillo's home, mother present, officers wore plain clothes (two detectives), one uniformed translator, no handcuffs or force, Castillo was told he could stop and was given written advisals | Court held not custodial: objective totality of circumstances (including age) showed a reasonable person in Castillo’s position would not have felt deprived of freedom to the degree associated with formal arrest; Appellate Court affirmed |
| Whether the trial court’s factual finding that Castillo was at home when officers arrived was clearly erroneous | (Pressed earlier) Evidence conflicted about whether Castillo was immediately present when officers arrived | Trial court credited mother’s unequivocal testimony that he was home; Appellate Court upheld that finding | Not reached substantively by Supreme Court (defendant abandoned this claim on appeal) |
| Whether court should exercise supervisory authority to require juvenile waiver forms to warn that statements may be used in adult criminal proceedings after transfer | Form’s language (“in a court of law”) was insufficient; juvenile suspects may be misled and are vulnerable—court should adopt prophylactic per se rule | No showing of pervasive problem; the police were not required under Miranda here because interrogation was noncustodial; supervisory power is extraordinary and unjustified on these facts | Court declined to exercise supervisory authority to adopt the requested per se rule (no pervasive problem shown; case-specific advisory not warranted) |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes Miranda custodial-interrogation warning requirement)
- J.D.B. v. North Carolina, 564 U.S. 261 (U.S. 2011) (a juvenile’s age is a relevant factor in the Miranda custody analysis)
- State v. Mangual, 311 Conn. 182 (Conn. 2014) (articulates nonexclusive list of factors for determining Miranda custody in home-interrogation cases)
- State v. Kirby, 280 Conn. 361 (Conn. 2006) (example where home interrogation was found noncustodial under totality of circumstances)