This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A child was charged with two counts of first-degree murder and conspiracy to commit murder involving the co-respondent's parents. The case arose after the child allegedly participated in the acts alongside another minor. The prosecution sought to transfer the case to district court, arguing the child was not amenable to treatment or rehabilitation through available facilities (paras 1, 3).
Procedural History
- Children's Court, February 1988: The court ordered a psychological evaluation to assess the child's amenability to treatment and later transferred the case to district court, finding the child not amenable to rehabilitation (paras 1, 3-4).
Parties' Submissions
- Respondent-Appellant (Child): Argued that his Fifth Amendment privilege against self-incrimination was violated when compelled to answer questions during a court-ordered psychological evaluation. He also contended that his waiver of constitutional rights before making statements to the police was not knowing, intelligent, or voluntary (paras 2, 5-7, 18).
- Plaintiff-Appellee (State): Asserted that the psychological evaluation was necessary to determine the child's amenability to treatment and that the court order protected the child from the use of his statements in future criminal proceedings. The State also argued that the child knowingly and voluntarily waived his rights before making statements to the police (paras 6, 10, 17).
Legal Issues
- Whether the child's Fifth Amendment privilege against self-incrimination was violated by the use of statements made during a court-ordered psychological evaluation (para 2).
- Whether the child's waiver of constitutional rights before making statements to the police was knowing, intelligent, and voluntary (para 2).
Disposition
- The Court of Appeals affirmed the children's court's orders transferring the case to district court and denying the motion to suppress the child's statements (para 21).
Reasons
Per Apodaca J. (Bivins CJ. and Donnelly J. concurring):
Fifth Amendment Privilege: The court held that the psychological evaluation did not violate the child's Fifth Amendment rights. The evaluation was limited to assessing amenability to treatment, and the court order expressly protected the child from the use of his statements in any future criminal proceedings. The court rejected the argument that the amenability phase constituted a "penalty phase" of criminal proceedings (paras 6-15).
Waiver of Rights: The court found substantial evidence supporting the children's court's determination that the child knowingly, intelligently, and voluntarily waived his constitutional rights before making statements to the police. Factors considered included the child's understanding of his Miranda rights, his decision to speak without counsel or a parent present, and his coherent and rational demeanor during questioning (paras 17-20).
Conclusion: The court concluded that the transfer process was properly conducted, and the child's constitutional rights were not violated. The orders of the children's court were affirmed (paras 21-22).