In re Gregory W., 27 N.Y.2d 55 (1970) 274 N.E.2d 57
A juvenile’s confession is inadmissible in juvenile delinquency proceedings if it is deemed involuntary based on the totality of the circumstances, considering the child’s age, mental state, the length and nature of the interrogation, and the presence or absence of counsel or parental guidance.
Summary
Gregory W., a 12-year-old with mental health issues, was interrogated for an extended period without adequate legal or parental support. He confessed to a crime he may not have committed, and his confession was used to adjudicate him a juvenile delinquent. The New York Court of Appeals reversed, holding that the confession was involuntary and thus inadmissible. The court emphasized the need for due process protections for juveniles, recognizing the quasi-criminal nature of juvenile delinquency proceedings and the vulnerability of children during police interrogations.
Facts
Two elderly women were assaulted, raped, and sodomized in Brooklyn. One of the women died. Based on the surviving victim’s limited description, the police took 12-year-old Gregory W. into custody. He was questioned about an unrelated crime and then about the assault and murder. Gregory, who had mental health issues, gave inconsistent statements. After hours of interrogation, he confessed to the crime. He later recanted parts of his confession when it was discovered he was in a psychiatric ward during the time of the crime.
Procedural History
The Family Court admitted Gregory’s confession and adjudicated him a juvenile delinquent. The Appellate Division affirmed. The New York Court of Appeals reversed, finding the confession involuntary and inadmissible, remanding the case to the Family Court.
Issue(s)
Whether the confession of a 12-year-old, mentally disturbed child, obtained after lengthy interrogation without adequate parental or legal counsel, is admissible in a juvenile delinquency proceeding.
Holding
No, because under the totality of the circumstances, the confession was involuntary and its admission violated the juvenile’s due process rights.
Court’s Reasoning
The court recognized that while Family Court proceedings are not criminal, they are quasi-criminal because they can result in a loss of personal freedom. Therefore, juveniles are entitled to due process protections. The court cited Section 711 of the Family Court Act, emphasizing its purpose “to provide due process of law…for considering a claim that a person is a juvenile delinquent.” The court found the interrogation was not conducted within a reasonable period, violating Family Court Act § 724. The court emphasized Gregory’s age, mental state, the length of the interrogation, and the absence of adequate parental or legal support, quoting Justice Douglas in Haley v. Ohio, 332 U.S. 596 (1948), that a child is “an easy victim of the law” and requires counsel and support to avoid coercion. The court found the detective’s tactics suggestive of coercion, rendering Gregory’s statements involuntary. The court stated, “Neither man nor child can be allowed to stand condemned by methods which flout constitutional requirements of due process of law.” The court also noted that the inconsistencies in the confession further demonstrated its unreliability.