A boy alleged to have written bomb threats on a bathroom wall at Decatur Middle School was deprived of his Miranda rights under police interrogation and his statements should have been suppressed, the Indiana Supreme Court ruled Wednesday.
Thirteen-year-old B.A. was alleged to have written the threat: “I will Got A bomb in the school Monday 8th 2016 not A Joke” on a bathroom wall in February 2016. After checking the premises on February 8. 2016, a vice principal and school resource officer removed B.A. from his school bus and escorted him to the vice principal’s office.
B.A. was interviewed by three uniformed school resource officers. Upon his confession, B.A. was suspended from school, and the school resource officers arrested him and took him to the Marion County Juvenile Detention Center.
The boy was adjudicated for committing false reporting and institutional criminal mischief, Level 6 felony and Class A misdemeanors if committed by an adult. He then moved to suppress the evidence from his interview, arguing that he was entitled to Miranda warnings because he was under custodial interrogation and officers failed to secure waiver of his Miranda rights under Indiana’s juvenile waiver statute.
The juvenile court denied the motion and found B.A. delinquent on both accounts, however the Indiana Supreme Court determined his statements should have been suppressed. The court also found that the trial court abused its discretion in admitting the statements.
“As the State points out, no one yelled at or threatened B.A. Still, the consistent police presence would place considerable coercive pressure on a reasonable student in B.A.’s situation,” Chief Justice Loretta Rush wrote Wednesday. “So this case lies solidly on the “custody” end of the student-confinement spectrum.”
The court reversed B.A.’s delinquency adjudications in B.A. v. State of Indiana 49S02-1709-JV-567 and remanded the case to the juvenile court.
The Indiana Court of Appeals previously reached the opposite conclusion, issuing a ruling in March 2017 affirming the juvenile court.