Law School Case Brief
State v. Callahan - 979 S.W.2d 577 (Tenn. 1998)
Juvenile waivers of the right to remain silent shall be analyzed under a totality-of-the-circumstances test that requires consideration of the following factors: (1) consideration of all circumstances surrounding the interrogation including the juvenile's age, experience, education, and intelligence; (2) the juvenile's capacity to understand the Miranda warnings and the consequences of the waiver; (3) the juvenile's familiarity with Miranda warnings or the ability to read and write in the language used to give the warnings; (4) any intoxication; (5) any mental disease, disorder, or retardation; and (6) the presence of a parent, guardian, or interested adult.
Defendant N.A.C., a 15-year old juvenile, was arrested for the murders of his mother and sister. His father granted the police permission to question defendant, and defendant was advised of his Miranda rights. After signing a waiver form, defendant made a statement concerning the murders. A drug screen indicated that defendant was not under the influence of any substances at the time he waived his right to remain silent. Thereafter, defendant filed a motion to suppress his statement, claiming that he should have been informed of the possibility of being prosecuted as an adult. The trial court denied defendant's motion to suppress. The trial court held that under the totality of the circumstances defendant knowingly and voluntarily waived his right to remain silent. Furthermore, the trial court rejected defendant's argument that a police officer is under an obligation to inform juveniles of the possibility they may be prosecuted as adults. The court of appeals affirmed. Defendant was granted leave to appeal and argued that both the Fifth Amendment to the United States Constitution and Article I, § 9 of the Tennessee Constitution mandated that a juvenile suspect be informed of the possibility of being prosecuted as an adult before the juvenile could make a knowing, intelligent, and voluntary waiver of the right against self-incrimination.
Should a juvenile suspect be informed of the possibility of being prosecuted as an adult before the juvenile can make a knowing, intelligent, and voluntary waiver of the right against self-incrimination?
The state supreme court affirmed the appellate court's decision affirming defendant's conviction. The court noted that whether a juvenile was prosecuted as an adult was a method of prosecution. Methods of prosecution were not in the purview of law enforcement officials. Accordingly, neither the Tennessee Constitution nor the United States Constitution required police officers to inform juveniles of the possibility that they might be prosecuted as adults. Moreover, the possibility of being tried as an adult was not a factor of the totality-of-the-circumstances test, and under the test, defendant made a voluntary waiver of his Miranda rights.
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