State v. Griffin
2017 Ark. 67
| Ark. | 2017Background
- On July 6–9, 2013, James Griffin (16) — in custody of Arkansas DHS — was arrested and interviewed by police; he signed a Miranda waiver and made incriminating statements on July 9.
- Griffin had been transferred from juvenile to adult detention after he was formally charged as an adult in one case (72CR-13-1127); the Springdale statement led to adult charges in a second case (72CR-13-1136) the day after the interview.
- Griffin moved to suppress the July 9 statement, arguing Ark. Code Ann. § 9-27-317(g) bars acceptance of a waiver of counsel while a juvenile is in DHS custody; he also raised an alternative voluntariness/competency argument.
- The Washington County Circuit Court granted suppression, ruling § 9-27-317(g) made his waiver ineffective because he was in DHS custody at the time of questioning.
- The State appealed interlocutorily, arguing the circuit court misinterpreted § 9-27-317(g) and contending the juvenile-code protections apply only to juvenile-court proceedings when the juvenile is ultimately prosecuted in circuit court.
- The Arkansas Supreme Court reversed and remanded, holding the circuit court erred and reaffirming prior precedent that § 9-27-317 protections are limited to juvenile-court proceedings when the juvenile is ultimately charged and tried in circuit court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 9-27-317(g) bars a waiver of counsel given while a juvenile is in DHS custody when the juvenile is later charged as an adult | Griffin: § 9-27-317(g) is an absolute prohibition — waiver invalid because he was in DHS custody at time of statement | State: Protections in § 9-27-317 apply only to juvenile-court proceedings; if prosecuted as an adult in circuit court, juvenile becomes subject to adult procedures and waiver is valid | Held: Reversed circuit court; following Boyd line, protections apply only to juvenile-court proceedings and do not bar admission when juvenile is charged/tried in circuit court as an adult |
| Whether the fact the juvenile was not yet charged as an adult at the time of the statement changes application of § 9-27-317 | Griffin: Timing matters; lack of an adult charge at interrogation means juvenile protections should apply | State: Ultimate charging decision governs; subsequent charging as adult brings adult procedures, so timing of charge does not bar admission | Held: Timing does not control; court follows prior rulings (Boyd/Ring) that ultimate prosecution in circuit court governs applicability |
| Whether Griffin’s DHS custody status distinguishes this case from Boyd/Ring and requires a different interpretation of § 9-27-317(g) | Griffin: DHS custody is materially different and warrants greater protection (absolute prohibition should apply) | State: No persuasive basis; prior cases consistently interpret the juvenile code as limited to juvenile-court proceedings regardless of custody status | Held: Rejected; DHS custody does not change application under existing precedent |
| Whether this Court should overrule Boyd and its progeny | Griffin: Argues Boyd should be overruled as producing perverse incentives and failing to protect juveniles in DHS custody | State: Court bound by stare decisis; legislature may amend statute if it disagrees | Held: Court declines to overrule Boyd/Ring; follows stare decisis and legislative role in changing law |
Key Cases Cited
- Boyd v. State, 313 Ark. 171, 853 S.W.2d 263 (interpreting § 9-27-317 and holding parental-consent waiver rule applies only to juvenile-court proceedings)
- Ring v. State, 320 Ark. 128, 894 S.W.2d 944 (reaffirming Boyd: ultimate charging in circuit court removes juvenile-code waiver protections)
- Jackson v. State, 359 Ark. 87, 194 S.W.3d 757 (applies Boyd/Ring principle to other juvenile-code protections when charged as adult)
- Ray v. State, 344 Ark. 136, 40 S.W.3d 243 (holds juvenile-code protections limited to juvenile proceedings)
- Misskelley v. State, 323 Ark. 449, 915 S.W.2d 702 (same line: parental consent requirement applies to juvenile-court proceedings)
- State v. L.P., 369 Ark. 21, 250 S.W.3d 248 (accepting State appeal where interpretation of § 9-27-317 warranted Supreme Court review)
- Corn v. Farmers Ins. Co., 2013 Ark. 444, 430 S.W.3d 655 (principle that this Court’s statutory interpretation becomes part of law and legislature may amend if it disagrees)