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Iowa Supreme Court Refuses Miranda Protection for Confession to Case Worker
The Iowa Supreme Court has affirmed a lower-court decision denying defendant Jess John Pearson's Motion to Suppress, based upon the Miranda case for a voluntary confession given to his social worker, who interviewed him after he had committed a crime. In so ruling, the court noted that the interview by his eight-year caseworker, who was not even aware of the crime before the unsolicited confession, did not constitute an arrest or restraint situation or one in which he would have felt some form of coercion. The ruling also constituted a case of first impression for the Iowa court in light of the case of J.D.B. v. North Carolina, 564 U.S., (2011), regarding custody issues of a thirteen-year old suspect.
Pearson at the time of his arrest was a runaway from the Bremwood Residential Treatment Center in Waverly, who proceeded to rob and beat an elderly, disabled man in his home with a cast-iron frying pan. When apprehended that same day by the Waterloo police, he refused to waive his Miranda rights and said he would not talk before he returned to Bremwood and spoke with his lawyer. The next morning, however, he promptly confessed to his social worker without his attorney present.
Under Miranda v. Arizona, 384 U.S. 436 (1966), a custodial investigation can trigger various warnings. Applying the J.D.B. decision, the court examined the issue of "whether there was a formal arrest or restraint on freedom of movement of the degree associated with formal arrest." Applying an objective test, the court concluded that the social worker "was not an agent or stalking horse for the Waterloo police: she had her own reasons as Pearson's case worker, to interview him." See: State v. Pearson, 804 N.W.2d 260 (Iowa, 2011).
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Related legal case
State v. Pearson
|Cite||804 N.W.2d 260 (Iowa, 2011)|
|Level||State Supreme Court|