In re M.C.
Missouri Court of Appeals
504 S.W.2d 641 (1974)
- Written by Meredith Hamilton Alley, JD
Facts
M.C. (defendant) was 14 years old when the state (plaintiff) charged him with delinquency as a result of theft, which carried the possibility of a lengthier loss of liberty than a theft charge in criminal court. While M.C. was in police custody, he allegedly made an incriminating statement. At trial, M.C. challenged the admissibility of the incriminating statement, arguing that the statement was involuntary. The trial court ruled that M.C. had the burden of proving that the incriminating statement was involuntary. M.C. was convicted of theft, given a suspended commitment to the custody of the state reform school, and placed in his parents’ custody under court supervision. M.C. appealed, arguing, among other things, that in delinquency matters, a juvenile should not have the burden of proving that an incriminatory statement was involuntary.
Rule of Law
Issue
Holding and Reasoning (Kelly, J.)
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