83 N.Y.2d 51 (1993)
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A juvenile offender’s confession is admissible, even if parental notification under CPL 140.20(6) is delayed, when the juvenile misrepresented their age and the police acted in good faith, reasonably believing they were dealing with an adult.
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Summary
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Yusef Salaam, a 15-year-old, was convicted of rape and robbery related to the Central Park jogger case. He argued his confession should be suppressed because police isolated him from his mother and other adults who sought to see him during questioning. The Court of Appeals affirmed the conviction, holding the confession admissible. Salaam misrepresented himself as 16, and police reasonably believed him. There was no evidence of police deception to isolate him. Questioning ceased immediately upon discovery of his true age. The court emphasized that the police acted diligently and in good faith under the circumstances.
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Facts
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On April 19, 1989, a group of youths assaulted several people in Central Park, with the most severe attack on a female jogger.r
Police investigating the assaults were told that Salaam was involved and was 16 or 17 years old.r
On April 20, police approached Salaam, who claimed to be 16 and presented a school transit pass supporting this claim.r
Police took Salaam to the precinct for questioning.r
Salaam received Miranda warnings and gave a statement implicating himself in the assaults.r
During questioning, Salaam’s aunt and a family friend (an Assistant U.S. Attorney) were denied access to him.r
Salaam’s mother arrived later and informed the police that he was actually 15. Questioning then ceased, and Salaam was allowed to see his mother.
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Procedural History
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Salaam was convicted in a jury trial for rape and robbery in the first degree, among other crimes.r
The Appellate Division affirmed his conviction.r
Salaam appealed to the Court of Appeals, arguing his confession should have been suppressed.
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Issue(s)
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Whether Salaam’s inculpatory statements should be suppressed because the police allegedly unlawfully isolated him from supportive adults during questioning, despite his misrepresentation of his age.r
Whether the police violated CPL 140.20(6) by failing to immediately notify Salaam’s parent or guardian of his arrest, given his initial claim of being 16 years old.
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Holding
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No, because there was no evidence of police deception or trickery to isolate Salaam, and he misrepresented himself as an adult.r
No, because Salaam’s misrepresentation of his age provided the police with reasonable justification to believe he was an adult, and they acted diligently to comply with statutory and constitutional responsibilities.r
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Court’s Reasoning
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The Court relied on precedent establishing that police deception or trickery to isolate a suspect is required for suppression. The Court distinguished this case from People v. Townsend and People v. Bevilacqua, where police actively concealed information or ignored requests for counsel.r
The Court noted that Salaam voluntarily accompanied the police and affirmatively misrepresented his age, providing