## Facts

- James Duggan, a Philadelphia meat market manager, attempted a night deposit of approximately $4,000 in cash, checks, and food stamps when he was confronted by at least two assailants and robbed.
- A witness later identified Eric Williams (also known as David Murphy) as one of the robbers.
- On February 6, 1980, detectives arrested Williams, who was 17½ years old at the time.
- Police contacted Williams’s father, Ollie Williams, informed him of the arrest and reasons, and brought him to the police station.
- Father and son briefly consulted privately before any Miranda warnings were administered.
- With the father present, detectives gave Miranda warnings, explained each right, and obtained Williams’s affirmative acknowledgments of understanding.
- Williams waived his rights and gave an incriminating statement in his father’s presence; both father and son signed the written confession.
- Williams had multiple prior juvenile delinquency adjudications, prior commitments to juvenile facilities, and was on probation at the time of this offense.

## Issues

1. Whether a juvenile’s confession must be suppressed because the juvenile did not have a private consultation with a parent after Miranda warnings and before waiving rights, where the parent was present during the warnings, waiver, and statement.
2. Whether, under the totality of the circumstances, the Commonwealth proved the juvenile’s Miranda waiver and confession were knowing, intelligent, and voluntary.

## Decision

- The Supreme Court of Pennsylvania affirmed the Superior Court and held the confession admissible.
- The court rejected a requirement that police must provide a private parent-juvenile consultation after Miranda warnings as a condition of a valid waiver.
- Applying a totality-of-the-circumstances test, the court concluded the Commonwealth met its burden to show a knowing, intelligent, and voluntary waiver and voluntary confession.
- The court emphasized the father’s presence and participation during warnings and waiver, the earlier private consultation, the absence of coercion, and the juvenile’s age and prior justice-system experience.

## Legal Principles

- The Commonwealth bears the burden to prove, by the totality of the circumstances, that a juvenile’s Miranda waiver and confession were knowing, intelligent, and voluntary.
- Close scrutiny is required for juvenile confessions, but Pennsylvania law does not impose rigid, per se procedural requirements beyond Miranda.
- The presence and involvement of a parent or other interested adult is an important factor in assessing voluntariness and comprehension, but it is not a constitutionally mandated sequence requiring a post-warning private consultation.
- Lack of coercion (e.g., no threats, promises, deprivation, or unduly prolonged interrogation) supports a finding that a confession is voluntary.

## Conclusion

The court held that a 17½-year-old’s confession was not suppressible solely because he lacked a private consultation with his father after receiving Miranda warnings; given the father’s presence during the warnings and waiver, a prior private discussion, the juvenile’s prior system experience, and no evidence of coercion, the waiver and confession were valid under the totality of the circumstances.


Commonwealth v. Williams, 475 A.2d 1283 (Pa. 1984)