People v. Steve M.

Seventeen-year-old Steve M. did not explicitly waive his Miranda rights, however police relied on an implied waiver to interrogate him, despite his youth, evident learning disabilities, and intoxication at the time of the interrogation. They then charged him for attempting to steal a bicycle.

Juvenile Law Center wrote an amicus letter to the California Supreme Court, in support of Steve’s Petition for Review, challenging the validity of a youth’s implied waiver. Our letter urged the court to grant review, arguing that Steve’s youth, learning disabilities, and intoxication at the time of the interrogation made it impossible for him to have the capacity to waive his rights. Our letter also emphasized that the unique vulnerabilities of youth—including their increased susceptibility to police coercion—entitle them to special protections during interrogations. 

The California Supreme Court denied Steve’s Petition for Review.