Commonwealth v. Leon L.

Police officers brought 14-year-old Leon L. and 13-year-old Carl C. (defendants) to the police station with their mothers to question the boys about an intentional fire that had destroyed property. Both families were relatively new to the United States and did not speak much English. A bilingual police officer translated during the interrogations. This officer gave Miranda warnings to the boys in Spanish and English and asked the mothers if they had understood the warnings. Both mothers said that they understood, and the mothers and the boys all signed Miranda waivers agreeing to let the boys speak with the police. Leon and Carl each initially denied any involvement in the fire. However, the interrogating officer exerted pressure by yelling and using aggressive body language and physical gestures, such as pounding the table. The officer also made it difficult for the mothers to speak with their sons and allegedly threatened one boy that he would be locked up alone if he did not confess. The boys were scared and crying and eventually submitted to the interrogating officer, claiming that they had been involved in the fire. At trial, the boys moved to suppress the confessions. The trial court suppressed the confessions because (1) the mothers had not truly understood the Miranda warnings and, therefore, were not interested adults who had helped the sons make valid, knowing waivers and (2) the totality of the circumstances showed that the boys’ statements were not voluntary, reliable confessions. The government (plaintiff) appealed.