## Facts

- A nurse was shot and killed in a hospital parking lot on March 22, 1973.
- Several months later, police arrested and interrogated Roger G., a 16–17-year-old juvenile, regarding the homicide.
- The evidence implicating Roger included equivocal eyewitness testimony, his possession of a .38-caliber pistol with inconclusive ballistics linkage, and a taped confession.
- During questioning, Roger initially resisted confessing and claimed an inability to remember.
- Officers increased pressure by warning that Roger could be jailed into his mid-twenties, could be certified to adult court, and could receive a life sentence.
- When Roger indicated he wanted to see the other suspects before speaking, officers responded that he would not see anyone except the court and reiterated the adult-court threat.
- Officers also implied that if Roger was “truthful” they would help him obtain favorable treatment such as probation or parole, but that if he did not cooperate he would receive “no way” of such relief.
- After these threats and implied promises, Roger confessed.
- The juvenile court adjudicated Roger a ward of the court based on a finding that he committed murder.

## Issues

1. Whether Roger’s confession was involuntary and inadmissible because officers threatened harsher treatment (including adult certification and life imprisonment) if he did not talk and promised assistance toward leniency (including probation or parole) if he did.
2. Whether such threats, promises, and representations, considered under the totality of circumstances and Roger’s juvenile status, overbore his will.

## Decision

- The Court of Appeal reversed the wardship adjudication.
- The court held the confession was involuntary on uncontradicted facts.
- The court concluded the confession was obtained through improper threats and promises, including threats of adult-court certification and implied assurances of help with parole or leniency.
- Because the confession was inadmissible and had been used to sustain the wardship finding, reversal was required.

## Legal Principles

- A confession is involuntary when obtained by police threats of harsher treatment conditioned on silence or noncooperation, coupled with promises or implied promises of leniency conditioned on confession.
- In assessing voluntariness, courts consider the totality of the circumstances, including the suspect’s age and vulnerability when the suspect is a juvenile.
- Police conduct is coercive where officers misrepresent their authority by suggesting they personally control decisions such as juvenile-to-adult certification or sentencing consequences and tie those outcomes to whether the suspect confesses.
- When uncontradicted facts establish coercion through threats and promises, the resulting confession is inadmissible.

## Conclusion

The court held that police obtained a juvenile’s confession through coercive threats of adult-court certification and severe punishment, along with implied promises of help toward parole or other favorable treatment, and reversed the resulting wardship adjudication because the confession was involuntary and inadmissible.


In re Roger G., 53 Cal. App. 3d 198 (Cal. Ct. App. 1975)