Arizona Court of Appeals Finds Young Defendant’s Confession Was Not Improperly Admitted at Trial

In a recent case before an Arizona court of appeals, the defendant in a murder and robbery case asked the court to find that his confession was made involuntarily. The defendant was charged when he was 16 years old, and he argued on appeal that when he confessed to the crime, he did not have the mental capacity to understand what he was doing. On appeal, the higher court affirmed the lower court’s decision and kept in place the original convictions and sentences.

Facts of the Case

According to the opinion, the defendant and a friend of his were found near the body of a murder victim in November 2016. Both individuals were brought in for questioning, and the defendant said he wanted to speak with an attorney before saying anything to the officers. The officers granted this request, and they put both individuals into a room while they waited for attorneys to arrive. The defendant and his friend did not know that the room was being monitored by video and audio recording.

The defendant and his friend began talking, and the defendant stated that he had fired shots into the back of the victim’s head. The State admitted this confession at trial, and the defendant was found guilty and sentenced to life imprisonment.

The Decision

On appeal, the defendant argued that his statement should not have been admitted at trial. He made the statement involuntarily, he said, and he did not realize what he was doing because of his young age. The defendant’s main issue was that the officers had created an atmosphere in which he felt forced to discuss the facts of the case. This environment, combined with the fact that the defendant was young and did not fully understand what was happening, meant that the resulting statement was made involuntarily. If the statement was made involuntarily, it should not have been admitted at trial.

The court reviewed the record and looked at the circumstances of the defendant’s arrest. It is true, said the court, that a confession must be made voluntarily for it to be admissible at trial. Here, however, the court found that the defendant’s confession was indeed voluntary. The defendant was not being interrogated by police at the time of his confession. No one had threatened him, intimidated him, or used force to make him start talking. Regarding his young age, the court found that the defendant had previous experience with police officers and that he should have been familiar with the process of being held in custody.

With these conclusions in mind, the court denied the defendant’s appeal.

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