Interrogating Juveniles; Custody, Beheler, & Common Sense

Interrogating Juveniles; Custody, Beheler, & Common Sense

By Robert C. Phillips
DDA: Retired
April, 2018

It is becoming increasingly recognized that juveniles present a unique problem in attempting to obtain incriminatory statements in the custodial interrogation setting.  It is estimated, for instance, that of the false confessions obtained by law enforcement, more than one third (35%) of such confessions are obtained from individuals under the age of 18.[1]

If you have difficulty accepting this premise, you should know that yet another appellate court decision has recently come down graphically illustrating this fact.   In In re I.F.,[2] California’s Third District Court of Appeal describes in encyclopedic detail the plight of a 12-year-old murder suspect as he is confronted by a series of interrogations that, although never completely successful, do eventually squeeze out of him enough in the way of contradictory statements to earn him a juvenile court magistrate’s true finding.

The Facts:

I.F.’s nightmare (not to mention the agony to which his entire family was about to be subjected) began on the morning of April 27, 2013.  B.F. (husband) and C.W. (wife), living in California’s Calaveras County with their blended family of six children, ages one to 15, all headed out to attend a Little League game, leaving only I.F. and his 8-year-old sister, L.F., home alone.  Just after noon, C.W. received a panicked call on her cellphone from I.F., telling her that ....

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