State v. Powell

Summary

The court affirmed the partial suppression of a 15-year-old’s statements made during her third police interview. Although the interview was noncustodial and Miranda warnings were not required, the court held that the trial court properly applied the juvenile-voluntariness factors and did not clearly err in finding the statements involuntary under the totality of the circumstances. The court concluded that the detective’s misleading handling of the right to counsel, together with the other circumstances of the interview, supported suppression of the statements made after the first nine minutes and thirty seconds.