State v. Daniel Jensen
161 Idaho 243
| Idaho Ct. App. | 2016Background
- At 17, Daniel Jensen allegedly put mouse poison in his mother’s coffee; mother and others drank it. Officers questioned Jensen at the house and later at juvenile detention; he made inculpatory statements on both occasions.
- Jensen was charged with attempted first-degree murder and other counts; the State invoked Idaho Code § 20-509 to automatically prosecute him as an adult.
- Jensen moved to declare I.C. § 20-509 unconstitutional (Eighth and Fourteenth Amendment challenges) and moved to suppress his pre-arrest and post-arrest statements. District court denied both motions.
- Jensen entered a conditional plea to felony poisoning (I.C. § 18-5501), preserving appeal on the two denials. He received a blended sentence (suspended) and was committed to juvenile and adult custody with retained jurisdiction.
- The Court of Appeals affirms: (1) I.C. § 20-509 is not unconstitutional as applied; (2) the trial court did not err in denying suppression of statements (no custodial Miranda violation on porch; valid Miranda waiver at detention center).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of I.C. § 20-509 under Eighth Amendment | Statute doesn’t itself punish; State: Eighth Amendment applies after conviction/sentencing only | Jensen: automatic waiver forecloses consideration of youth, producing disproportionate exposure to adult punishment | Statute is procedural, not a punishment; Eighth Amendment not triggered by automatic waiver; sentencing phase allows juvenile considerations (blended/juvenile options). |
| Constitutionality of I.C. § 20-509 under Fourteenth Amendment (due process/liberty interest) | Kent/juvenile jurisprudence requires individualized waiver; recent juvenile sentencing precedents show youth matters | State: Idaho precedent holds no vested right to juvenile adjudication under §20-509; no liberty interest deprived | No liberty interest in juvenile adjudication under Idaho law; prior precedent controls; due process not violated; blended sentence shows youth considered. |
| Suppression: statements before arrest (porch questioning) — Miranda applicability | Jensen: questioning on porch was custodial interrogation; Miranda warnings required | State: objective custody test not met (brief, calm, familiar setting; free to leave; friend present); officer’s subjective intent irrelevant | Not custodial; Miranda warnings not required; district court’s factual findings upheld. |
| Suppression: statements after arrest at detention center — Miranda waiver validity | Jensen: as a juvenile, absence of parents and maturity undermined voluntariness of waiver | State: written waiver, officer reviewed rights, juvenile understood and initialed each, interview calm | Totality of circumstances supports a knowing, voluntary, intelligent waiver; waiver valid; statements admissible. |
Key Cases Cited
- Kent v. United States, 383 U.S. 541 (recognizes importance of procedural protections in juvenile waiver decisions)
- Miranda v. Arizona, 384 U.S. 436 (established custodial interrogation warnings requirement)
- Berkemer v. McCarty, 468 U.S. 420 (defines custody in Miranda context as restraint comparable to formal arrest)
- State v. Anderson, 108 Idaho 454 (Idaho precedent: no statutory right to be prosecuted as juvenile under § 20-509)