In re Joseph H.

367 P.3d 1 (2015)

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In re Joseph H.

California Supreme Court
367 P.3d 1 (2015)

Facts

Joseph H. (petitioner) was a 10-year-old boy who had a difficult childhood. Joseph’s mother did numerous drugs while pregnant with him. Joseph suffered from attention deficit hyperactive disorder (ADHD), and his intelligence was low to average. Joseph was terribly neglected and physically abused by his mother and sexually abused by her boyfriend. At the age of three or four, Joseph and his younger sister were placed in the custody of their father, who had a problem with drugs and alcohol and who physically abused Joseph. One night, Joseph shot and killed his father. Joseph confessed to the shooting while in police custody. A detective read Joseph his Miranda rights, and Joseph waived them. Regardless of the presumption of incapacity provided by statute for a child Joseph’s age, a juvenile court held that Joseph understood that his acts were wrong and intentionally discharged a gun, resulting in death. The court determined that Joseph’s acts would have constituted second-degree murder if the acts had been performed by an adult. The juvenile court committed Joseph to the Division of Juvenile Justice and sentenced him to serve 40 years to life in a secure facility. Joseph appealed to the California Court of Appeal and argued that the juvenile court had erred in considering statements that Joseph viewed as having been made in violation of his rights under Miranda. The California Court of Appeal affirmed and found that Joseph understood his rights and that his waiver of his Miranda rights was valid. Joseph petitioned for review by the California Supreme Court, which denied his petition.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

Dissent (Liu, J.)

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