## Facts

- Police were patrolling a neighborhood that had experienced an increase in burglaries when they observed Alva Stiff, a school-aged minor, with Lydell Curry during school hours.
- About an hour later, the officers again saw Stiff and Curry, this time running between houses and across lawns; when the youths noticed the police, Curry ran away and Stiff stopped.
- An officer called Stiff to the squad car and asked why he had been running; Stiff asked whether he would “be in trouble” if he told the officers everything, and an officer replied that it depended on what he had done.
- The officers placed Stiff in the back of the squad car as the encounter continued.
- The State filed a juvenile delinquency petition alleging Stiff committed one burglary and two murders; after adjudicatory proceedings, the juvenile court found the allegations proved beyond a reasonable doubt.
- After a dispositional hearing, the juvenile court adjudged Stiff delinquent and committed him to the custody of the Department of Corrections.
- In the juvenile proceedings, Stiff challenged the fairness of the tribunal through motions seeking a change in the place of trial or, alternatively, assignment of a judge from another county; the trial court denied that request.
- Stiff also challenged the admissibility of his statements to law enforcement, arguing (among other things) that the police unlawfully detained him when they put him in the squad car and that his admissions were not voluntary given his age and the circumstances of questioning.

## Issues

1. Whether police unlawfully detained (or arrested) the juvenile by placing him in the squad car during the on-scene encounter, such that his ensuing statements and related evidence should have been suppressed.
2. Whether the juvenile court erred in denying Stiff’s request for a change of place of trial or for assignment of a judge from another county based on alleged local prejudice and publicity.
3. Whether Stiff’s confession/admissions were voluntary under constitutional standards applicable to juveniles.
4. Whether the evidence was sufficient to prove beyond a reasonable doubt the burglary and two murders supporting the delinquency adjudication.

## Decision

- The Illinois Appellate Court affirmed the adjudication of delinquency and the commitment order.
- The court rejected the claim that placing Stiff in the squad car constituted an unlawful detention requiring suppression, concluding the officers’ actions were justified by the circumstances of the encounter and did not invalidate the investigation or resulting statements.
- The court found no abuse of discretion in denying a change of place of trial or the request for an out-of-county judge because the record did not show prejudice so pervasive that a fair hearing could not be held, or actual judicial bias requiring reassignment.
- Applying a totality-of-the-circumstances analysis, the court upheld admission of Stiff’s statements as voluntary notwithstanding his youth, because the record did not establish coercion or an overborne will.
- Considering the properly admitted evidence, the court held the proof was sufficient to support findings beyond a reasonable doubt on burglary and both murders.

## Legal Principles

- A brief investigatory stop is permissible when officers can point to specific and articulable facts supporting reasonable suspicion of criminal activity; measures taken during the stop are assessed for reasonableness in light of the situation.
- Placement of a suspect in a police vehicle during an investigatory encounter does not automatically convert the encounter into an arrest; the legality turns on whether the restraint was reasonable under the circumstances.
- Suppression principles apply in juvenile delinquency proceedings when admissions or evidence are claimed to be the product of unlawful police conduct.
- A change of place of trial requires a concrete showing that community prejudice is so widespread that a fair and impartial proceeding cannot be held; generalized publicity concerns are not enough without supporting proof.
- Requests for assignment of a different judge beyond statutory substitution require a record showing actual bias or circumstances demonstrating an inability to receive a fair hearing.
- Voluntariness of a juvenile’s confession is evaluated under the totality of the circumstances; age and the presence or absence of a parent are relevant considerations but are not dispositive by themselves.
- On review of delinquency findings, the question is whether, viewing the evidence in the light most favorable to the State, a rational trier of fact could find the essential elements proved beyond a reasonable doubt.

## Conclusion

In *In re Stiff*, the Illinois Appellate Court affirmed the delinquency adjudication and commitment of 14-year-old Alva Stiff for burglary and two murders, holding that the officers’ on-scene handling of Stiff—including placing him in the squad car—did not require suppression, that the trial court properly denied requests to move the case or import an out-of-county judge absent a showing of actual prejudice or bias, that Stiff’s admissions were voluntary under the totality of the circumstances, and that the evidence supported the findings beyond a reasonable doubt.


In re Stiff, 32 Ill. App. 3d 971, 336 N.E.2d 619 (1975)