In re I.F.

B.F. and C.W. lived in Calaveras County with a blended family that included six children, ranging from one to 15 years of age. Most of the family attended a Little League baseball game on April 27, 2013, leaving the house at approximately 7:00 a.m. Appellant I.F. then age 12, and his sister L.F., age 8, were home alone on that morning; during the course of the morning, someone entered L.F.’s bedroom and stabbed her to death. Later that day, and in the days that followed, I.F. made a series of inconsistent and cumulatively incriminating statements to police. A petition was filed under Welfare and Institutions Code section 602 alleging that I.F. committed murder and personally used a knife in the commission of the offense. Following a contested jurisdictional hearing, the juvenile court sustained the petition and found true the allegation that I.F. personally used a knife in the commission of the crime. I.F. appealed, arguing the juvenile court erroneously admitted his pre-arrest statements in violation of Miranda v. Arizona, 384 U.S. 436 (1966). After review, the Court of Appeal agreed that two of four challenged statements were inadmissible. Because the Miranda error was not harmless beyond a reasonable doubt under Chapman v. California, 386 U.S. 18 (1967), the Court reversed and remanded for further proceedings. View "In re I.F." on Justia Law