State v. G.O.

Summary

The Kansas Supreme Court held that G.O.'s statements to police were involuntary under both the Fifth Amendment voluntariness standard and the Fourteenth Amendment Due Process Clause. The detective's repeated assurances that G.O. was not under arrest, was not in trouble, and was speaking to help his stepsister negated the Miranda warning and, combined with G.O.'s age, anxiety, educational difficulties, and lack of law-enforcement experience, overbore his will. The court reversed the Court of Appeals, affirmed suppression by the district court, and rejected reliability as a constitutional requirement for suppressing an involuntary confession.