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Name: In re Elias V.
Case #: A140263
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 06/09/2015

Coercive police techniques employed during interrogation of minor rendered his confession involuntary. Elias, a 13-year-old, was accused of molesting a young female neighbor (Pen. Code, § 288, subd. (a)). Prior to and at the time of the jurisdictional hearing, the defense moved to suppress statements Elias made to police, arguing that they were involuntary and inadmissible (Miranda v. Arizona (1966) 384 U.S. 436). The motion was denied, and the allegations were sustained. Elias appealed. Held: Reversed. The use of an involuntary statement in a delinquency proceeding violates a minor’s due process rights. The admissibility of a statement is judged on the totality of the circumstances that existed when the confession was obtained. Coercive police conduct or improper influences may support a finding the confession was involuntary, especially with respect to juveniles, whose obedience to authority and lower social status render them more vulnerable during interrogations. (See J.D.B. v. North Carolina (2012) 131 S.Ct. 2394 [potential for false confessions is most acute in cases where police interrogate juveniles].) Here, after extensively analyzing Miranda, interrogation training materials, false confession research, and the circumstances of Elias’ interrogation, the Court of Appeal concluded that Elias’ statements were involuntary based on a combination of the following factors: (1) his youth (which rendered him most susceptible to influence and outside pressures); (2) the absence of any evidence corroborating the statements; and (3) the likelihood that the detective’s use of deception and overbearing tactics would induce involuntary and untrustworthy incriminating admissions. In addition to all these circumstances, the court noted that the detective, against the advice of all police manuals and other authorities, used custodial interrogation as the only means of evaluating Elias’ truthfulness.