In Re the Welfare of G.S.P.
2000 Minn. App. LEXIS 374, 2000 WL 462221, 610 N.W.2d 651 (2000)
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Rule of Law:
A juvenile questioned at school by a school official in the presence of and with the active participation of a law enforcement officer is subject to custodial interrogation requiring a Miranda warning if, under the totality of the circumstances, a reasonable person in the juvenile's position would believe they were restrained to a degree associated with a formal arrest.
Facts:
- A custodian at North Middle School found a backpack containing a BB gun in the boys' locker room.
- The custodian gave the backpack to Assistant Principal James Wheeler, who identified it as belonging to 12-year-old G.S.P.
- Wheeler called Grand Rapids police officer Brian Johnson, a school liaison officer, to the school.
- Wheeler and Officer Johnson, who was in uniform, removed G.S.P. from his seventh-grade classroom and took him to Wheeler's office.
- Inside the office, with a school counselor and teacher also present, Wheeler told G.S.P. he had no choice but to answer their questions.
- Wheeler questioned G.S.P. about the backpack's contents and then revealed the BB gun.
- G.S.P. became upset and admitted the gun was his, stating he had forgotten it was in his backpack.
- Officer Johnson then read from a criminal statute, informed G.S.P. he would be charged, and proceeded to ask more questions about the gun and his intentions.
Procedural Posture:
- A juvenile delinquency petition was filed against G.S.P. in the district court, charging him with possession of a BB gun on school property.
- G.S.P. filed a motion to suppress the statements he made to the assistant principal and the police officer.
- The district court held a combined omnibus hearing and trial.
- The court denied G.S.P.'s motion to suppress, ruling that he was not in custody and that his statements were voluntary.
- The trial court found G.S.P. delinquent but stayed the adjudication for six months pending good behavior.
- G.S.P. (appellant) appealed the district court's order to the Minnesota Court of Appeals, and the State (appellee) moved to dismiss the appeal.
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Issue:
Was a 12-year-old student, questioned in the assistant principal's office by the assistant principal and a uniformed police officer, subjected to a custodial interrogation that required a Miranda warning?
Opinions:
Majority - Huspeni, J.
Yes. G.S.P. was subjected to a custodial interrogation that required a Miranda warning. Under the objective test for custody, a reasonable person in G.S.P.'s circumstances would have believed they were under restraint to a degree associated with a formal arrest. The court reasoned that the combination of G.S.P.'s young age (12), his unfamiliarity with disciplinary proceedings, being removed from class by a uniformed officer and an assistant principal, and being explicitly told he had no choice but to answer questions created a coercive environment. Furthermore, the officer's active participation, including tape-recording the interview and quoting from a criminal statute, transformed the situation from a school disciplinary inquiry into a custodial interrogation designed to elicit an incriminating response for criminal prosecution. Because no Miranda warning was given, G.S.P.'s statements must be suppressed.
Analysis:
This decision clarifies the boundary between school disciplinary inquiries and custodial interrogations, particularly when school liaison officers are involved. It establishes that the mere presence of an officer is not determinative, but their active participation in questioning a juvenile within a coercive school environment can trigger Fifth Amendment protections. The case serves as a caution to school administrators and law enforcement that their collaboration in student interviews can create a custodial setting requiring Miranda warnings. This precedent forces a more careful approach in joint investigations on school grounds to avoid unconstitutional interrogations of minors.
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