Clark v. State

Summary

The Court affirmed Clark’s convictions, holding that the evidence was constitutionally sufficient to establish that he was a party to the felony murder and related firearm offense even though the evidence indicated that his codefendant fired the fatal shot. The Court also held that the trial court properly used a totality-of-the-circumstances test for Clark’s juvenile Miranda waiver, and that Clark failed to establish plain error or ineffective assistance of counsel. The Court clarified that the nine-factor framework previously associated with juvenile Miranda waivers is not mandatory or exclusive.