State v. Jones, 2012 ME 126

Jones was charged with manslaughter (Class A) after his infant daughter died from injuries she sustained.
He entered a conditional guilty plea to manslaughter and preserved the right to appeal suppression and bind-over rulings.
Detectives interrogated Jones in three settings: at the hospital, at his apartment, and at the Maine State Police barracks.
Jones confessed to throwing the baby against her crib, which preceded her hospitalization and death.
During the bind-over hearing, the Juvenile Court admitted hearsay from Mountain View Center staff; Jones was bound over to be tried as an adult.
The Superior Court denied the suppression motion; Jones was sentenced to 15 years with four years to serve and six years suspended.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether custodial interrogation occurred	Jones argues Miranda warnings were required during custodial interrogations.	Jones contends custody existed under Michaud factors for all three interrogations.	No custody found; Miranda not triggered for any interrogation.
Whether juvenile status affected custody analysis	Jones asserts age should have been a significant custody factor per J.D.B.	Jones argues the court failed to factor his juvenile status into custody analysis.	Court properly considered age; it was not a significant factor given circumstances.
Whether the confession was voluntary	Jones contends questioning violated due process and Miranda.	Jones maintains the interrogations were coercive and involuntary.	Confession deemed voluntary; totality of circumstances supported voluntariness.
Whether hearsay at bind-over violated due process	Admission of hearsay from Mountain View staff could undermine reliability.	Hearsay is unreliable and should be excluded under due process concerns.	Hearsay deemed reliable and its admission did not violate due process; evidence limited to appropriate bind-over context.

State v. Bridges, 829 A.2d 247 (Me. 2003) (custody determination is mixed question of fact and law; totality of circumstances)
State v. Michaud, 724 A.2d 1222 (Me. 1998) (factors for custodial interrogation analysis)
State v. Rosado, 669 A.2d 180 (Me. 1996) (due process in bind-over hearings; reliance on hearsay considerations)
James, 797 A.2d 732 (Me. 2002) (reliability of hearsay in administrative adjudicatory proceedings)
State v. Prescott, 48 A.3d 218 (Me. 2012) (Miranda rights and custody analysis framework)
J.D.B. v. North Carolina, 131 S. Ct. 2394 (2011) (juvenile age must be considered in custody determinations)
State v. Conner, 977 A.2d 1003 (Me. 2009) (infer findings when no Rule 41A(d) motion for further findings)
State v. Ann Marie C., 407 A.2d 715 (Me. 1979) (counsel requirement not per se for juvenile interrogations; statutory caveats)
State v. Rosado, 669 A.2d 180 (Me. 1996) (due process and bind-over context; evidentiary considerations)
Beheler, 463 U.S. 1121 (U.S. 1983) (custody assessment not satisfied by mere focus of investigation)