In the Interest of Christopher W.
285 S.C. 329, 329 S.E.2d 769 (1985)
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Rule of Law:
The admissibility of a minor's confession depends on its voluntariness, which is determined not by a per se rule requiring the presence of a parent or counsel, but by the totality of the circumstances, including the minor's age, intelligence, education, experience, and ability to comprehend the meaning of their statement.
Facts:
- A fire broke out at a church in York County.
- Police arrived at the scene around 10:00 p.m. and found eleven-year-old Christopher W., who was out past his probation curfew.
- When an officer asked Christopher why he was out past curfew, Christopher unresponsively stated he did not start the fire.
- The officer took Christopher into custody, read him his Miranda rights, and began an interrogation.
- During the interrogation, the officer brought a Bible into the room and asked Christopher if he could place his hand on it and swear he had not been in the church.
- Immediately after this, Christopher confessed, stating, "I didn’t know it was going to be that big a fire."
- The following morning, Christopher confessed again to a different officer after being read his Miranda rights a second time.
Procedural Posture:
- The State initiated a delinquency proceeding against Christopher W. in family court.
- At trial, the family court admitted Christopher's first confession into evidence, despite expressing displeasure with the interrogation method.
- The family court found Christopher W. guilty of arson.
- Christopher W. (appellant) appealed the family court's decision, arguing the court erred in admitting his confession.
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Issue:
Does a police officer's use of a Bible during the interrogation of an eleven-year-old suspect render the resulting confession involuntary under the totality of the circumstances test?
Opinions:
Majority - Shaw, Judge
No, the confession was not involuntary. A minor's confession is admissible if it was voluntarily given, which is determined by the totality of the circumstances. While the court disapproved of the officer's interrogation tactic, other factors demonstrated the confession's voluntariness. The court found that although Christopher is young, his testimony showed him to be intelligent, quick, and articulate. Furthermore, Christopher had several prior experiences with the police and testified that he understood his right to remain silent and the meaning of his statement, satisfying the voluntariness test by a preponderance of the evidence.
Analysis:
This case reinforces the flexible 'totality of the circumstances' test for juvenile confessions in South Carolina, rejecting a more rigid, protective rule that would automatically exclude confessions made without a parent or lawyer present. It demonstrates that a minor's personal characteristics, such as being 'street-wise' and having prior police contact, can outweigh their young age and seemingly coercive interrogation tactics. This ruling provides courts with significant discretion and signifies that even questionable police methods may not invalidate a confession if the minor is deemed to have sufficient understanding and experience.
