State v. Powell

Summary

The court affirmed suppression of the juvenile appellee’s inculpatory statements made after the first 9 minutes and 30 seconds of her third police interview and suppression of her related written statement. Although the interview was noncustodial and Miranda warnings were not constitutionally required, the court held that the juvenile’s voluntariness must still be assessed under the Riley factors as part of the totality of the circumstances. The court concluded that the trial court’s factual findings were supported by the record and that the circumstances showed the juvenile did not knowingly, intelligently, freely, and voluntarily continue speaking with police.