## Facts

- Deputy Sheriff Bailey suspected, but lacked probable cause to believe, that 14-year-old R.L.J. had participated in recent burglaries.
- Before contacting the juvenile, Bailey spoke with R.L.J.’s father and obtained the father’s permission to take R.L.J. to the sheriff’s office for questioning.
- Bailey located R.L.J. and told him he wanted to talk with him at the sheriff’s office.
- When R.L.J. asked why, Bailey said he preferred to explain at the sheriff’s office rather than on the spot.
- R.L.J. agreed to ride with Bailey to the sheriff’s office.
- Bailey did not tell R.L.J. that he was not required to go to the sheriff’s office or that he could refuse the request.
- At the sheriff’s office, Bailey advised R.L.J. of his Miranda rights.
- After approximately 30–40 minutes of questioning, R.L.J. made an incriminating statement confessing to the offense under investigation.
- R.L.J. was charged in juvenile proceedings and, at the delinquency hearing, testified that he believed he had to go with Bailey because Bailey was a law enforcement officer.
- The juvenile court denied a motion to suppress the confession, admitted it, and adjudicated R.L.J. delinquent.
- R.L.J. appealed the adjudication, challenging the admissibility of his confession.

## Issues

1. Whether R.L.J.’s station-house confession should have been suppressed on the ground that it was involuntary, given his age, the officer’s request that he come to the sheriff’s office without telling him he could refuse, and the absence of a parent during questioning despite the father’s prior permission.
2. Whether parental notification and the father’s expressed lack of objection to questioning supported admission of the confession even though the parent was not physically present during interrogation.

## Decision

- The First District Court of Appeal affirmed the delinquency adjudication.
- The court upheld admission of R.L.J.’s confession, concluding that the circumstances did not require suppression.
- The court treated the father’s notification and permission as a significant circumstance supporting voluntariness, along with Miranda warnings and the brief duration of questioning.

## Legal Principles

- A juvenile confession is evaluated for voluntariness under the totality of the circumstances, with special attention to the child’s age and the setting of the interrogation.
- Miranda warnings and a valid waiver are important factors favoring admissibility, but they are assessed together with all surrounding circumstances.
- The absence of a parent from the interrogation room does not automatically render a juvenile’s confession inadmissible; prior parental notification and the parent’s lack of objection may support a finding of voluntariness.
- An officer’s failure to tell a juvenile that he may refuse to accompany the officer to a station is relevant to whether the statement was voluntary, but it is not alone determinative without additional coercive circumstances.

## Conclusion

The appellate court affirmed the adjudication of delinquency, holding that the juvenile’s station-house confession was properly admitted because, considering the total circumstances—including Miranda warnings, the limited duration of questioning, and the father’s notification and consent—the statement was voluntary and not subject to suppression merely because the parent was not present during questioning or because the juvenile was not told he could refuse to go to the sheriff’s office.


In the Interest of R.L.J., 336 So. 2d 132 (1976)