Massachusetts Appeals Court Rules Juvenile’s Age Must Be Considered in Miranda Analysis

The Massachusetts Appeals Court today ruled that a juvenile’s age must be considered by a judge in determining whether the juvenile was subjected to the functional equivalent of an interrogation.  The name of the case is Commonwealth v. Quinones. 

On July 21, 2015, the victim was shot in the leg while walking on his friend’s driveway in Lynn.  A witness reported a kid rode to the driveway on a bike, pulled out a gun, and shot the victim.  The police arrived in short order and searched the surrounding neighborhood, finding the defendant and another person inside a vehicle.  The defendant, who was 16 years old, was lying down in the back seat.  A bike had been left on the ground near the car.  The defendant told the cops he knew the owner of the car but when the cops contacted the owner, he said the defendant was not authorized to be in the vehicle.  The defendant was arrested and transported to the Lynn Police Department to be booked.  The defendant asked one of the officers why he was being locked up and the officer answered, before telling the defendant if he didn’t “clean up his act,” he would end up in serious trouble.  The defendant responded that he had been “proving himself.”  The police subsequently obtained video surveillance that implicated the defendant in the shooting and at trial his statement to the officer about “proving himself” was admitted to the jury.  He was convicted, as a youthful offender, of armed assault with intent to murder and assault and battery with a dangerous weapon.  He appealed and the Appeals Court affirmed.

The defendant had moved to suppress his statement to the police about “proving himself,” but a juvenile court judge denied his motion.  The Appeals Court concluded the defendant’s statement was properly admitted.  Miranda warnings advise a criminal suspect that he has a number of rights, including the right to be represented by an attorney and the right to remain silent.  However, a suspect is entitled to receive Miranda warnings only when: (1) he is in police custody; and (2) he is being interrogated by the police.  If a suspect’s statement was not the result of custodial interrogation, there was no Miranda violation.  In this case, the parties agreed the defendant was in police custody at the time he made the statement.  The question was whether he was also the subject of a police interrogation.  Interrogation includes direct questioning or its functional equivalent.  The “functional equivalent” of direct questioning includes all actions or words of police officers that the officers knew were reasonably likely to cause the suspect to make an incriminating statement.  For example, when a police officer advises a suspect to “get the matter off his chest by making a statement,” he has engaged in the functional equivalent of an interrogation.  In this case, the Appeals Court ruled that when considering whether a juvenile suspect is the subject of the functional equivalent of an interrogation, the trial court is obligated to factor the juvenile’s age into the analysis.  After all, a juvenile would be expected to react differently to a police officer than an experienced adult would.

Ultimately, even after factoring in the juvenile’s age, the Appeals Court agreed with the juvenile court judge that the defendant was not subject to the functional equivalent of an interrogation.  The officer’s statement to the defendant was advice, not an invitation to make an incriminating statement.  Accordingly, the defendant was properly convicted.