In re Watson - 47 Ohio St. 3d 86, 548 N.E.2d 210 (1989)

Rule:

In construing whether a juvenile defendant's confession has been involuntarily induced, courts should consider the standard, which looks to the totality of the circumstances, including the age, mentality, and prior criminal experience of the accused; the length, intensity and frequency of interrogation; the existence of physical deprivation or mistreatment; and the existence of threat or inducement. Given the above standard, the trial court can properly determine whether the juvenile appreciated his rights and voluntarily waived them in the absence of an interested adult or parent.

Facts:

The juvenile defendants took part in an incident in which one of the juveniles attempted to take money from the victim, who threatened him for doing so. The juvenile defendants joined a group of others who assaulted the victim, leading to the victim’s death. The juvenile defendants went to the police station, where a police officer explained their Miranda rights. The juvenile defendants agreed to waiving their rights, and subsequently gave taped statements. The juvenile defendants were convicted of offenses which, if committed by an adult, would constitute complicity to murder. One was also convicted of an offense that would constitute petty theft if committed by an adult. The Court of Appeals for Hamilton County (Ohio) affirmed their convictions, and they appealed.

Issue:

1. Did the juvenile defendants voluntarily waive their Miranda rights in the absence of an interested adult or parent? 
2. Did the trial court properly deny the juvenile defendants’ motions for separate trials? 

Answer:

1) Yes. 2) Yes.

Conclusion:

The court affirmed their convictions, holding that their statements regarding their involvement in the incident were voluntarily made. The court declined to adopt the "independent advice/interested adult" standard for determining the voluntariness of a juvenile's confession. The juveniles' family members were not present during their statements, but the totality of the circumstances, including the juveniles' ages, the reading of their rights, and their written signatures stating that they understood each right were sufficient to support a finding that the statements and waivers were voluntary. The court also held that the refusal of the trial court to try the juveniles separately did not prejudice their cases. Each of their statements were redacted to avoid prejudice to the other, and they had a trial to the judge, so there was no chance that a jury would use the statement of one juvenile to the prejudice of the other.