The Court of Appeal held that the trial erred by admitting statements police obtained in violation of Miranda v. Arizona (1966) 384 U.S. 436and Edwards v Arizona (1981) 451 U.S. 477, and that the error was not harmless. In so holding, the Court found that the officers continued to interrogate appellant after he unambiguously invoked his right to counsel, and that appellant’s decision to speak to the officers nine seconds after the officers stopped speaking was the result of the improper interrogation and not appellant’s voluntary initiation of discussion with police.
Victory Categories: Miranda and Voluntariness
[Published Decision] Court of Appeal held that the juvenile court erred in admitting evidence of appellant’s pre-arrest statements to police, which were made in violation of Miranda, and that the erroneous admission of evidence prejudiced appellant. In reaching this decision, the Court found that officers transformed appellant’s home into a “police-dominated atmosphere,” when five officers, all armed with guns, arrived at appellant’s home at 6:00 a.m. on the morning of the incident and proceeded to interrogate appellant as a suspect (and not a witness). The Court emphasized that appellant never consented to police questioning, was a minor, and was led to believe he was not free to leave or end the interrogation.