C.J. v. State
In a unanimous opinion, the Indiana Court of Appeals rejected the validity of 12-year-old C.J.'s Miranda waiver that C.J., who had an IQ of 70, signed during an interrogation alone with police after only a 23-second "consultation" with his mother. The State petitioned for transfer to the Indiana Supreme Court.
Juvenile Law Center filed an amicus brief in the Supreme Court of Indiana asking the court to affirm the ruling of the Court of Appeals, in accordance with both prevailing case law and current research, if the court concludes that transfer is appropriate. Specifically, our brief highlighted developmental research that demonstrates children lack essential capacities to waive their Miranda rights and require heightened protections to determine the voluntariness of juvenile confessions. We further argued that parental involvement does not enhance the reliability of youth's waiver of their Miranda rights.
The Indiana Supreme Court denied the State's petition to transfer.