## Facts

- Police investigated reports that two juvenile girls, including 13-year-old Cindy Ann Spalding, had taken part in a “sex-party” involving other juveniles and adults and had drugged their parents to leave home at night.
- Officers interviewed the girls and obtained statements describing the events; the interviews occurred with adults present (including parents), and the girls were upset and crying during questioning.
- After taking the statements, police held Spalding (and the other juvenile) overnight in protective custody.
- The State filed juvenile petitions alleging the girls were delinquent and/or “children in need of supervision” (CINS) under Maryland juvenile law.
- Before the juvenile hearing, Spalding moved to suppress statements she made to police (and related statements to juvenile-services and evaluation personnel), arguing lack of *Miranda* warnings and violation of the privilege against self-incrimination.
- The juvenile master denied suppression and found Spalding in need of care and treatment as a CINS, not delinquent; she was committed to the Department of Juvenile Services for placement and treatment.
- After further evaluation and additional juvenile proceedings, the Circuit Court for Baltimore County, sitting as a juvenile court, held a de novo hearing and again adjudicated Spalding a CINS and committed her for placement and treatment.
- The Court of Special Appeals affirmed, holding that Spalding’s compelled testimony did not violate the privilege against self-incrimination.
- Spalding sought review in the Court of Appeals of Maryland, challenging admission of her statements, the requirement that she testify, and limits placed on cross-examining a police officer about voluntariness and *Miranda* warnings.

## Issues

1. In a CINS proceeding, must a juvenile’s statements to police be suppressed under the Fifth Amendment and *Miranda*?
2. Does requiring the juvenile to testify at a CINS hearing violate the constitutional privilege against self-incrimination?
3. Did the juvenile court err by restricting cross-examination of the police officer concerning voluntariness and *Miranda* warnings in connection with the juvenile’s statements?

## Decision

- The Court of Appeals of Maryland affirmed.
- The court held that the CINS proceeding at issue was not “essentially criminal,” so the Fifth Amendment protections applicable to criminal prosecutions—including *Miranda*’s custodial-interrogation safeguards as applied in delinquency cases—did not require suppression of Spalding’s statements in this CINS adjudication.
- The court rejected Spalding’s claim that she was constitutionally entitled to refuse to testify in the CINS case, reasoning that the privilege against self-incrimination is tied to being compelled to be a witness against oneself in a “criminal case,” and this proceeding was remedial and supervisory rather than punitive.
- The court also upheld the limits on cross-examination of the officer regarding voluntariness and *Miranda*, concluding that, in this noncriminal CINS context, the challenged restrictions did not amount to a constitutional violation.

## Legal Principles

- Courts evaluate the substance of a proceeding, not just its label, when deciding whether constitutional protections linked to “criminal cases” apply; a nominally civil or juvenile matter can trigger Fifth Amendment protections if it is, in substance, essentially criminal.
- The Fifth Amendment privilege against self-incrimination protects against compelled testimony in a “criminal case”; its application depends on whether the proceeding functions as a criminal prosecution in purpose and effect.
- *In re Gault* applies core due-process safeguards to juvenile delinquency proceedings, but those protections do not automatically extend to every category of juvenile court jurisdiction; a treatment-oriented CINS proceeding may be treated differently from delinquency.
- *Miranda* warnings are tied to custodial interrogation in a criminal-law setting; when the proceeding is noncriminal and directed toward supervision and treatment rather than punishment, the absence of *Miranda* warnings does not necessarily require exclusion of a juvenile’s statements in the CINS adjudication.

## Conclusion

In *In re Matter of Spalding*, the Court of Appeals of Maryland affirmed a CINS adjudication and commitment to juvenile services, holding that the proceeding was not essentially criminal; therefore, the juvenile’s statements to police were not subject to suppression under *Miranda* and the Fifth Amendment in the same manner as in delinquency or criminal prosecutions, and neither compelled testimony nor the challenged limits on cross-examination violated the privilege against self-incrimination in this CINS context.


In re Matter of Spalding, 332 A.2d 246 (1975)