## Facts

- The State initiated a juvenile delinquency proceeding against M.C., who was 14 years old, based on an alleged theft.
- The delinquency charge exposed M.C. to the possibility of a longer loss of liberty than a theft charge in criminal court.
- While in police custody, M.C. allegedly made an incriminating statement regarding the theft.
- At the delinquency hearing, the State offered the statement into evidence.
- M.C., through counsel, objected and argued that the statement was involuntary.
- The juvenile court ruled that M.C. bore the burden of proving the statement was involuntary and, applying that allocation, admitted the statement.
- The juvenile court found M.C. delinquent based on theft, imposed a suspended commitment to the custody of the state reform school, and placed M.C. in his parents’ custody under court supervision.
- M.C. appealed, arguing that the juvenile court improperly placed the burden on him to prove involuntariness.

## Issues

1. In a juvenile delinquency proceeding, when the State seeks to admit a juvenile’s incriminating custodial statement and voluntariness is challenged, does the State have the burden to prove voluntariness, or does the juvenile have the burden to prove involuntariness?

## Decision

- The Missouri Court of Appeals reversed and remanded.
- The court held the juvenile court erred by allocating to M.C. the burden of proving his statement was involuntary.
- The court held that, in delinquency proceedings where a juvenile’s liberty is at stake, the State must establish that an incriminating statement was voluntary before it may be admitted.

## Legal Principles

- The State bears the burden to establish the voluntariness of a juvenile’s incriminating statement when the statement is offered in a delinquency proceeding and voluntariness is put in issue.
- A juvenile delinquency adjudication that can result in a restraint on liberty requires due process protections comparable to those applied in criminal proceedings for purposes of admitting confessions.
- A court may not admit a challenged confession on the ground that the juvenile failed to prove coercion; the proper inquiry is whether the State has shown the statement was voluntary.
- Voluntariness in the juvenile setting is evaluated from the totality of the circumstances, including factors tied to youth such as age and susceptibility during custodial questioning.

## Conclusion

Because the juvenile court placed on M.C. the burden to prove his custodial statement was involuntary, the Missouri Court of Appeals reversed the delinquency adjudication and remanded, holding that the State must establish voluntariness as a condition of admitting a juvenile’s incriminating statement in a delinquency proceeding.


In re M.C., 504 S.W.2d 641 (1974)