AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• A thirteen-year-old child, referred to as Child, was interrogated by three investigators in connection with the murder of Angel Vale. During the interrogation, Child made inculpatory statements regarding the burglary of Vale’s home. Child was arrested following the interrogation. The interrogation took place with Child's mother present, and Child was read his Miranda rights, which he appeared to understand according to the officers' testimony (paras 3-4).

Procedural History

• Appeal from the District Court of Roosevelt County, Drew D. Tatum, District Judge.
• Certiorari Granted, February 6, 2015, No. 34,995.
• Released for Publication March 31, 2015.

Parties' Submissions

• Child-Appellant: Argued that the State did not successfully rebut the presumption of inadmissibility of his statements given his age, contending that his statements during the interrogation were inadmissible against him due to his age and the statutory presumption against admissibility (para 1).
• State of New Mexico, Plaintiff-Appellee: Argued that the standard for rebutting the presumption of inadmissibility was met, presenting evidence from the investigating officers and Child's teacher regarding his personal traits to support the finding that he had the ability to knowingly, intelligently, and voluntarily waive his rights (paras 6-7).

Legal Issues

• Whether the State successfully rebutted the presumption of inadmissibility of statements made by a thirteen-year-old child under Section 32A-2-14(F).
• Whether the district court erred in denying Child's motion to suppress his statements.
• Whether Child was entitled to a twelve-member jury instead of six.

Disposition

• The court reversed the district court's denial of the motion to suppress Child's statements and remanded for a new trial.
• The court affirmed the district court's denial of Child's motion to sever, request for a bill of particulars, and demand for a twelve-person jury (para 2).

Reasons

• The court concluded that the State did not present clear and convincing evidence to rebut the presumption that Child was incapable of a valid waiver of his rights under Section 32A-2-14(F). The evidence presented by the State was deemed insufficient to establish that Child had the maturity and intelligence of an average fifteen-year-old child to understand his situation and the rights he possessed. The court emphasized the need for a hearing equivalent to a competency hearing in quality of evidence to assess a thirteen-year-old child's developmental status regarding the ability to waive Fifth Amendment rights. The court established that rebutting the presumption requires clear and convincing evidence that the child's personal traits give him an above-average ability to knowingly, intelligently, and voluntarily waive his rights. The court found that the testimony provided by the investigating officers and Child's teacher did not meet this burden, as it was based on limited interactions and did not adequately compare Child's abilities and maturity to the developmental level of an average fifteen-year-old child (paras 8-24).