California Court of Appeal: Police Created Atmosphere of Custodial Interrogation Requiring Miranda Warnings Even Though Prearrest Interview Occurred in Teen Suspect’s Home
by Douglas Ankney
The California Court of Appeal, First Appellate District, ruled that the coercive atmosphere created by police during a prearrest interview of a teen suspect in his own home made it a custodial interrogation requiring advisement of rights pursuant to Miranda v Arizona, 384 U.S. 436 (1966), and therefore, any admissions made by the suspect were erroneously admitted into evidence.
Ralph C. was stabbed in the left bicep during an incident involving Andrew G. and Matthew W. (The parties were identified by first name to protect their identities.) The Napa County District Attorney filed a juvenile wardship petition alleging Matthew had committed several offenses, including assault with a deadly weapon in violation of California Penal Code § 245 (a)(1).
At the jurisdictional hearing on the petition, defense counsel objected to the testimony of Napa Police Detective Brendt Keown. As Keown was about to testify regarding the prearrest statements Matthew had given, defense counsel objected on the ground of “lack of foundation regarding Miranda warning.” Keown was voir dired regarding the circumstances surrounding Matthew’s statements, and the judge overruled the objection.
At the hearing, Matthew testified that Ralph had shoved Andrew as the two squared off, apparently to fight. Fearing his friend Andrew would be hurt by the much larger and older Ralph, Matthew shouted, “Leave my friend alone” and showed Ralph that he (Matthew) was armed with a knife. Ralph then turned toward Matthew and said “now you want to fight.” Ralph lunged at Matthew, and Matthew pushed him off with both hands. The knife was still in his right hand and stabbed Ralph.
Keown was called in rebuttal. He testified that Matthew had said nothing about Ralph lunging at him in his prearrest statement. Nor did he mention that he showed Ralph the knife.
At the conclusion of the hearing, the juvenile court framed the issue it had to resolve as whether Matthew acted in self-defense or defense of another. Based in part on Keown’s testimony regarding Matthew’s prearrest statement, the court reasoned Matthew’s testimony about Ralph lunging at him was not credible. Consequently, the court concluded Matthew was not acting in self-defense. The juvenile court found true all allegations in the petition except for a “great bodily injury causing paralysis” enhancement. Matthew was ultimately declared a ward of the court and placed on probation.
Matthew appealed, arguing, inter alia, the juvenile court improperly admitted his prearrest statements to police in violation of Miranda.
Because the juvenile court did not explain its reasoning for overruling defense counsel’s objection to Keown’s testimony, the Court of Appeal independently reviewed the record and applied the relevant law. See In re I.F.,20 Cal. App. 5th 735 (2018) (where trial court makes no factual findings on dispositive issue, appellate court need not defer to the trial court and may independently review the record and apply the relevant law).
The Court noted that the dispositive issue in the case was whether Matthew was subject to a custodial interrogation when questioned by police in his home. An objective standard is used to determine whether a person is in custody for Miranda purposes, the Court stated. See I.F. The inquiry focuses on whether, in light of the totality of circumstances, “a reasonable person would interpret the restraints used by the police as tantamount to a formal arrest,” the Court explained, noting that a wide variety of factors are considered with no one factor being dispositive. Instead, the Court stated that “we look at the interplay and combined effect of all the circumstance to determine whether on balance they created a coercive atmosphere such that a reasonable person would have experienced a restraint tantamount to an arrest.” See Id.
With juvenile suspects, age is an additional factor to consider in the Miranda analysis when the age was known by the police at the time of questioning. See J.D.B. v. North Carolina, 564 U.S. 261 (2011).
In finding that Matthew’s prearrest interview was a custodial interrogation for Miranda purposes, the Court observed it was initiated by police after learning from Andrew that Matthew had stabbed Ralph. When officers interview a person as a suspect instead of as a witness, it is a factor that weighs in favor of custodial interrogation. See People v. Stansbury, 889 P.2d 588 (Cal. 1995).
Police initiating contact instead of the defendant also favors custodial interrogation. I.F. In reviewing the circumstances surrounding the contact with the defendant, courts seek to determine whether on balance the police created a coercive atmosphere such that a reasonable person would have experienced restraint tantamount to an arrest. People v. Aguilera, 51 Cal. App. 4th 1151 (1996). That is, would a reasonable person in the minor’s position have felt free to end the questioning and leave? I.F.
The Court observed that Keown’s questioning of Matthew during the interview was accusatory, signaling to a reasonable person he is a suspect and not free to leave. Other factors suggesting the interrogation was custodial included the fact that five uniformed officers arrived at Matthew’s home at 6:00 a.m. while it was still dark outside. See Id. Although Matthew’s mother consented to the police questioning him, he never consented, and no one ever asked him for his consent. See In re Anthony L., 43 Cal. App. 5th 438 (2019). Additionally, even though Keown released two officers, at least two other uniformed police officers—plus Keown—remained in the home throughout the interrogation. All of them were armed with guns. See I.F. One officer stood behind Matthew with the other at the front door, and Keown sat across the kitchen table from Matthew. See Anthony L. When Matthew complained he was cold, Keown did not allow him to retrieve a blanket from his bedroom but instead removed a blanket from a couch and handed it to Matthew, indicating Matthew wasn’t free to move about, according to the Court. See Miranda.
Keown never informed Matthew he was free to terminate the interrogation at any time or that he was free to leave. See Anthony L. Considering that Matthew was still a minor and living at home with his mother, the Court stated that it was particularly significant that when his mother asked to be present for the questioning of Matthew, Keown denied her request. See United States v. Craighead, 539 F.3d 1073 (9th Cir. 2008). Finally, Matthew was arrested at the conclusion of the interrogation. See Anthony L. Based on these factors, the Court concluded the interrogation was custodial. Because Matthew’s statements were obtained in violation of Miranda, the Court ruled that the juvenile court erred in admitting evidence of Matthew’s statements.
The Court next concluded the error was not harmless. To be harmless error, it must be clear beyond a reasonable doubt that the error did not contribute to the verdict. Chapman v. California, 386 U.S. 18 (1967). Under Chapman, the appropriate inquiry is “not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict actually rendered in this trial was surely unattributable to the error.” People v. Quartermain,941 P.2d 788 (Cal. 1997). Because the juvenile court relied on Matthew’s statements when concluding his self-defense testimony was not credible, it was not clear beyond a reasonable doubt the error did not contribute to the verdict, the Court ruled.
Accordingly, the Court reversed the juvenile court’s jurisdictional findings and dispositional order. See: In re Matthew W., 2021 Cal. App. LEXIS 566 (2021).
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In re Matthew W.
|Cite||2021 Cal. App. LEXIS 566 (2021)|
|Level||State Court of Appeals|