Miranda custody analysis in Illinois

2024The Court recognized that “children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave,” leading it to hold that “a child’s age properly informs the Miranda custody analysis.” Id. at 264-65 . ¶ 121 Illinois uses a “totality of the circumstances” analysis to decide if a juvenile’s confession is voluntary or involuntary.

2017See, e.g., Miller v. Alabama, 567 U.S. 460 , ___, ___, 132 S. Ct. 2455, 2464, 2468 (2012) (“children are constitutionally different from adults for purposes of sentencing,” and “in imposing a State’s harshest penalties, a sentencer misses too much if he treats every child as an adult”); J.D.B., 564 U.S. at 265 (“a child’s age properly informs the Miranda custody analysis”). ¶ 25 In J.D.B., the Supreme Court addressed whether the age of a child subjected to police questioning is relevant under Miranda v. Arizona, 384 U.S. 436 (1966).

2016The court declared: "The same rationale that requires modification of the reasonable person standard to take into account the general characteristics of 1 After our supreme court issued its decision in Braggs, the United States Supreme Court reversed the Ninth Circuit's decision in Alvarado, finding that "[the Supreme Court's] opinions applying the Miranda custody test have not mentioned the suspect's age, much less mandated its consideration." Yarborough v. Alvarado, 541 U.S. 652, 666 (2004).

2016The court declared: “The same rationale that requires modification of the reasonable person standard to take into account the general characteristics 1 After our supreme court issued its decision in Braggs, the United States Supreme Court reversed the Ninth Circuit’s decision in Alvarado, finding that “[the Supreme Court’s] opinions applying the Miranda custody test have not mentioned the suspect’s age, much less mandated its consideration.” Yarborough v. Alvarado, 541 U.S. 652, 666 (2004).

2024People v. Travis, 2013 IL App (3d) 110170, ¶ 54 (citing People v. Murdock, 2012 IL 112362, ¶ 30 ).

2015See People v. Travis, 2013 IL App (3d) 110170, ¶ 44 .

2015Assuming, without deciding, that the definition of “custodial interrogation” in section - 13 - 5-401.5(a) of the Juvenile Court Act also applies to section 5-170(a), we will use the Miranda custody test to address both parties’ contentions as to whether respondent was in custody when questioned by Detective Adams. ¶ 50 Whether a person is in custody, and thus whether the warnings set forth in Miranda v. Arizona, 384 U.S. 436 (1966), are required, involves two discrete inquiries: “ ‘first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a

2015Braggs, 209 Ill. 2d at 508-10 ; see also J.D.B., 564 U.S. at ___ , 131 S. Ct. at 2399 (“a child’s age properly informs the Miranda custody analysis”).

2015Assuming, without deciding, that the definition of “custodial interrogation” in section - 13 - 5-401.5(a) of the Juvenile Court Act also applies to section 5-170(a), we will use the Miranda custody test to address both parties’ contentions as to whether respondent was in custody when questioned by Detective Adams. ¶ 50 Whether a person is in custody, and thus whether the warnings set forth in Miranda v. Arizona, 384 U.S. 436 (1966), are required, involves two discrete inquiries: “ ‘first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a

2015Assuming, without deciding, that the definition of “custodial interrogation” in section - 13 - 5-401.5(a) of the Juvenile Court Act also applies to section 5-170(a), we will use the Miranda custody test to address both parties’ contentions as to whether respondent was in custody when questioned by Detective Adams. ¶ 50 Whether a person is in custody, and thus whether the warnings set forth in Miranda v. Arizona, 384 U.S. 436 (1966), are required, involves two discrete inquiries: “ ‘first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a

2017See, e.g., Miller v. Alabama, 567 U.S. 460 , ___, ___, 132 S. Ct. 2455, 2464, 2468 (2012) (“children are constitutionally different from adults for purposes of sentencing,” and “in imposing a State’s harshest penalties, a sentencer misses too much if he treats every child as an adult”); J.D.B., 564 U.S. at 265 (“a child’s age properly informs the Miranda custody analysis”). ¶ 25 In J.D.B., the Supreme Court addressed whether the age of a child subjected to police questioning is relevant under Miranda v. Arizona, 384 U.S. 436 (1966).

2017See, e.g., Miller v. Alabama, 567 U.S. 460 , ___, ___, 132 S. Ct. 2455, 2464, 2468 (2012) (“children are constitutionally different from adults for purposes of sentencing,” and “in imposing a State’s harshest penalties, a sentencer misses too much if he treats every child as an adult”); J.D.B., 564 U.S. at 265 (“a child’s age properly informs the Miranda custody analysis”). ¶ 25 In J.D.B., the Supreme Court addressed whether the age of a child subjected to police questioning is relevant under Miranda v. Arizona, 384 U.S. 436 (1966).