People v. Stephen J.B., 23 N.Y.2d 611 (1969)
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A voluntary confession made after full Miranda warnings is not automatically inadmissible solely because the defendant made earlier unwarned statements; the court must consider the totality of circumstances to determine if the later confession was truly voluntary.
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Summary
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Stephen J.B., a 16-year-old, was arrested for car theft. He initially made incriminating statements without full Miranda warnings. Later, after being fully advised of his rights, he confessed again, identifying the driver and admitting to the theft. The initial unwarned statements were suppressed, but the subsequent confession was admitted at trial, leading to his adjudication as a youthful offender. The New York Court of Appeals affirmed, holding that the later confession was admissible because it was voluntary and made after a knowing waiver of rights, despite the earlier inadmissible statements. The court emphasized that the key is whether the coercive effect of the initial unwarned statement tainted the subsequent confession.
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Facts
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On April 23, 1967, Stephen J.B. was apprehended in a stolen car.r
Patrolman Rabusch initially advised him of his right to an attorney and the right to remain silent, but did not inform him of his right to appointed counsel if indigent or that his statements could be used against him. Stephen admitted the car was stolen.r
Sergeant O’Donnell arrived and, without any Miranda warnings, asked Stephen why he ran. Stephen replied he believed the car was stolen.r
Sergeant O’Donnell then fully advised Stephen of his Miranda rights. Stephen waived these rights and confessed to stealing the car, also identifying the driver.r
Later, at the police station, he was re-advised of his rights and provided a written confession.r
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Procedural History
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A Huntley hearing was held to determine the voluntariness of Stephen’s admissions and confessions.r
The hearing Judge suppressed the initial oral admissions made before the full Miranda warnings.r
The Judge admitted the later oral confession, finding Stephen had been fully informed of and voluntarily waived his rights.r
Stephen pleaded guilty and was adjudicated a youthful offender; sentence was suspended and he was placed on probation.r
The Appellate Division unanimously affirmed.r
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Issue(s)
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Whether a confession, obtained after full Miranda warnings and a valid waiver, is rendered inadmissible solely because earlier statements were obtained without adequate Miranda warnings.r
Whether a minor can waive his constitutional rights without parental consent.r
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Holding
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No, because the voluntariness of a subsequent confession, given after proper Miranda warnings, must be determined by considering the totality of the circumstances; the prior inadmissible statement does not automatically taint the later confession.r
Yes, because whether a minor knowingly and intelligently waived his rights is a question of fact to be determined from the totality of the circumstances, including age, intelligence, education, and experience.r
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Court’s Reasoning
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The Court reasoned that while prior improperly obtained statements are a factor in determining the voluntariness of a subsequent confession, they do not automatically render the later confession inadmissible. Citing Lyons v. Oklahoma, 322 U.S. 596 (1944), the Court emphasized that the key question is whether the later confession was voluntary.r
The Court noted that the Supreme Court has never held that