State v. Burrell
697 N.W.2d 579, 2005 Minn. LEXIS 270, 2005 WL 1175752 (2005)
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Rule of Law:
Under the totality of the circumstances, a juvenile's Miranda waiver is rendered invalid when police deny the juvenile's repeated requests to speak with a parent and employ deceptive interrogation tactics before the waiver is secured.
Facts:
- On November 22, 2002, 11-year-old Tyesha Edwards was killed by a stray bullet while doing homework in her Minneapolis home.
- Police learned that a teenager named Timothy Oliver was the intended target of the shooting.
- Oliver identified the shooter as a 15- to 17-year-old male named 'Skits,' whom police later identified as 16-year-old Myon Burrell.
- Minneapolis police arrested Burrell and placed him in a video-recorded interrogation room.
- Before being read his Miranda rights, Burrell asked to call his mother three times but was denied by officers.
- Also before the Miranda warning, investigators told Burrell that his codefendants, Hans Williams and Ike Tyson, were implicating him in the shooting, which was a mischaracterization of the facts.
- After the Miranda warning was administered, Burrell asked to speak with his mother ten more times, and each request was denied.
- During the interrogation, Burrell's mother arrived at the police station and told an investigator that she and Burrell had arrived in Minneapolis the day before the shooting, contradicting Burrell's initial alibi.
Procedural Posture:
- Myon Burrell, along with Hans Williams and Ike Tyson, was indicted by a Hennepin County grand jury for first-degree murder.
- Burrell filed a pretrial motion in the district court to suppress his videotaped interrogation, arguing his Miranda waiver was ineffective because he was denied access to his mother.
- The district court denied the motion, ruling that the waiver was knowing, intelligent, and voluntary, and that there is no constitutional right for a juvenile to speak with a parent.
- At trial, the jury viewed the entire videotaped interrogation and found Burrell guilty on all charges.
- The district court entered a conviction and sentenced Burrell to life in prison plus consecutive terms for other charges.
- Burrell appealed his conviction to the Minnesota Supreme Court, raising several claims of error, including the admission of his interrogation.
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Issue:
Under the totality of the circumstances, is a juvenile's Miranda waiver knowing, intelligent, and voluntary when police repeatedly deny his requests to speak with his mother and mischaracterize evidence against him before the warning is administered?
Opinions:
Majority - Justice Anderson
The juvenile's Miranda waiver was not knowing, intelligent, and voluntary under these circumstances. The state failed to meet its burden of proving the waiver was valid due to the combination of police denying Burrell's repeated requests to speak with a parent and the pre-Miranda mischaracterization of evidence against him. The court must make a subjective factual inquiry into the totality of the circumstances, which includes the juvenile's age, maturity, experience, and the nature of the interrogation. In this case, the police crossed the line by denying access to a trusted parent, which Burrell clearly desired for counsel, and using deception to secure the waiver. Therefore, the statement obtained was inadmissible, and its admission at trial was not harmless error, requiring a new trial.
Concurring - Justice Hanson
While agreeing with the majority's ultimate decision to reverse the conviction, I write separately to emphasize different grounds. Although Burrell never unambiguously invoked his right to counsel or to remain silent, and his requests to speak to his mother could be interpreted as wanting to notify her of his whereabouts rather than seeking legal advice, the cumulative effect of the police conduct was problematic. The investigators' mischaracterizations, while perhaps not coercive enough standing alone to make an innocent person confess, combined with the denial of parental access created circumstances that undermined the validity of the waiver. However, I disagree with the majority's harmless error analysis - Burrell's statements were exculpatory rather than confessional, and the eyewitness testimony of Timothy Oliver provided strong evidence of guilt independent of the interrogation.
Analysis:
This case significantly clarifies the application of the 'totality of the circumstances' test for juvenile Miranda waivers in Minnesota. It establishes that police denial of a juvenile's repeated requests for a parent, especially when combined with deceptive interrogation tactics, can be sufficient to invalidate a waiver. The decision places a heavy burden on the state to prove a juvenile's waiver was voluntary under such conditions and serves as a strong caution to law enforcement against isolating juvenile suspects from parental contact. This precedent requires trial courts to scrutinize not just the juvenile's characteristics but also the specific police conduct leading up to the waiver.
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