Juvenile Defenders Association of Pennsylvania (JDAP): Juvenile Justice Supreme Court Review 2003-2004 Term

Juvenile Justice Supreme Court Review 2003-2004 Term

6th Amendment

Crawford v. Washington, 124 S.Ct. 1354 (March 8, 2004)
Applying the Sixth Amendment’s confrontation clause, the Court ruled that “testimonial” evidence is inadmissible hearsay unless the witness is “unavailable” and the defendant had a prior opportunity to cross examine. Overrules Ohio v. Roberts, the court’s 1980 decision permitting significant hearsay exceptions.

Blakely v. Washington, 124 S.Ct. 2531 (June 24, 2004)
Apprendi applies to sentencing within statutory maximums if a statute requires a judge to make additional findings, not required of the jury, in order to increase a sentence. Before this decision, every federal circuit ruled that the sentencing guidelines were safe from Apprendi decision, and now circuits are split.

5th Amendment

Missouri v. Seibert, 124 S. Ct. 2601 (June 28, 2004)
“Two stage interrogation techniques are impermissible.” To question a defendant before they are warned “is to render Miranda warnings ineffective by waiting for a particular opportune time to give them, after the suspect has already confessed.”

Yarborough v. Alvarado, 124 S. Ct. 2140 (June 1, 2004)
The two step inquiry for whether an accused is in custody evaluates the circumstances of the interrogation and whether a reasonable person would have felt at liberty to terminate the conversation. It does not allow for special consideration for the reasonable person’s youth and inexperience in the justice system.

U.S. v. Patane, 124 S. Ct. 2620 (June 28, 2004)
“Because the Miranda rule protects against violation of the Self-Incrimination Clause, which, in turn, is not implicated by the introduction at trial of physical evidence resulting from voluntary statements,” physical evidence resulting from unwarned statements are admissible.

4th Amendment

Hiibel v. 6th Judicial District Court of Nevada, 124 S. Ct. 2451 (June 21, 2004)
A law requiring a suspect to reveal his name in the course of a valid Terry stop is consistent with 4th Amendment prohibitions against unreasonable searches and seizures. Request must be “reasonably related to the circumstances justifying the stop.”

U.S. v. Banks, 124 S. Ct. 521 (Dec 2, 2003)
Once an exigency has occurred, offices may forcibly enter a premises with a warrant after they have knocked and announced their presence and received no response after only 15 to 20 seconds.

Maryland v Pringle, 123 S. Ct. 1571 (December 15, 2003)
No general rule can be created to evaluate probable cause, but here, arrest was valid where money was found in a glove compartment of a car in which three passengers all denied knowledge of it, and drugs were found after driver consented to a search.

Thornton v. US, 124 S. Ct. 2127 (May 24, 2004)
When an arrestee is a “recent occupant” of a vehicle, the police may search that vehicle “incident to the arrest” even if arrestee left the vehicle before he was apprehended.

Illinois v. Lidster, 123 S. Ct. 1928 (January 13, 2004)
The court upheld “suspicionless” roadblock stops reasonably related to investigation of a specific crime, as opposed to looking for evidence of ongoing crimes. This is a continuation of the Court’s holding that people do not have the same privacy interest in their cars as they do their homes.

Prepared by Angela C. Vigil
Baker & McKenzie
Director of Pro Bono and Public Service

Pennsylvania Juvenile Defenders

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Juvenile Justice Supreme Court Review 2003-2004 Term

6th Amendment

5th Amendment

4th Amendment