Confession - Juveniles

Favorable and Noteworthy Decisions in the Supreme Court and Federal Appellate Courts

United States v. Juvenile Male, 595 F.3d 885 (9th Cir. 2010)

The requirements of 18 U.S.C. § 5033 apply even if the law enforcement officer is unaware of the suspect’s age. The requirement applies, even if the defendant gives a false birthday to the police officer, thus causing the police officer not to know his juvenile status.

United States v. L.M.K., 149 F.3d 1033 (9th Cir. 1998)

Holding the defendant for 33 hours before she was brought to a magistrate violated 18 U.S.C. § 5033. The failure to notify the juvenile’s parents in a reasonable time, another violation of the Act. The juvenile’s statements should have been suppressed but the failure to do so was not reversible error.