State v. Butler

Juvenile Law Center wrote an amicus brief in support of Tyler B., a 16-year-old who was arrested, questioned, handcuffed, and eventually subjected to a blood draw at school, after being held for two hours behind closed doors by five adults, including two law enforcement officers, without access to his parents.

We argued that the trial court was right in granting Tyler B.’s motion to suppress evidence derived from the blood draw, as the law enforcement official lacked a warrant and Tyler did not voluntarily consent to the search.

Specifically, we argued that ample precedent in this and related areas supports a holding that Tyler’s age and other circumstances must be considered in assessing if he voluntarily consented to the blood draw. For example, in the United States Supreme Court’s ruling in J.D.B. v. North Carolina, the Court held that a youth’s age properly informs the analysis of whether a youth is in custody for purposes of Miranda v. Arizona. Courts must recognize the unique attributes of youth—for example, that they are more immature than adults and susceptible to coercion—when assessing whether their encounters with police pass constitutional muster.

Similarly, the Arizona Supreme Court has held that to provide juveniles confronted by the police with the same level of Fifth Amendment protection afforded to adults, courts must recognize that youth are different from adults when assessing the voluntariness of their confessions. The same principles apply with equal force here in determining the voluntariness of a youth’s alleged consent to search. 

The Arizona Supreme Court held that “factors such as age and the presence of parents” should be considered “when assessing the voluntariness of [a youth’s] consent to a search” and that, in this case, sufficient evidence supports the trial court’s finding that Tyler did not voluntarily consent to the blood draw.