## Facts

- Police detectives went to J.B.J.’s school and asked to speak with him in connection with a report alleging that he had engaged in delinquent conduct.
- The detectives interviewed J.B.J. in a school office.
- Shortly after a detective described the allegations in the report, J.B.J. confessed while still in the school office.
- After the confession, J.B.J. gave the school-resource officer his home phone number but said his mother would not be home.
- The school-resource officer began calling to try to reach J.B.J.’s mother.
- The detectives took J.B.J. into custody and left the school while the school-resource officer continued trying to contact J.B.J.’s parents.
- After multiple unsuccessful attempts to reach the mother, the school-resource officer called J.B.J.’s father at work.
- About an hour and a half after J.B.J. was taken into custody, the school-resource officer spoke with J.B.J.’s father and informed him that J.B.J. had been taken into custody.
- J.B.J. was adjudicated delinquent in juvenile court.
- J.B.J. appealed, challenging the admission of his schoolhouse confession based on Texas Family Code requirements, including parent-notification timing after a juvenile is taken into custody.

## Issues

1. Whether J.B.J.’s oral confession at school was a custodial “statement of a child” requiring compliance with the Texas Family Code procedures governing admissibility of juvenile statements.
2. Whether the delay in notifying a parent after J.B.J. was taken into custody required suppression of the confession J.B.J. gave at school.

## Decision

- The court of appeals affirmed the delinquency adjudication.
- The court held the oral confession made in the school office was not shown to be a custodial “statement of a child” that triggered the Family Code’s formal admissibility requirements for custodial statements.
- The court rejected suppression based on parent-notification timing, reasoning that the officers and school-resource officer made continuing efforts to contact a parent and the father was notified about ninety minutes after custody began.
- The court concluded that the later timing of parental notice did not require exclusion of the earlier school confession under these circumstances.

## Legal Principles

- Texas Family Code provisions governing the admissibility of a child’s custodial statement apply when the child is in custody and the statement is obtained through custodial interrogation; an informal oral admission during school questioning is not automatically treated as a statutorily regulated custodial statement.
- Whether a juvenile is “in custody” depends on the circumstances of the encounter, including the degree of restraint and whether a reasonable person in the juvenile’s position would feel free to end the interview.
- The Family Code requires prompt parental notification after a child is taken into custody; reasonableness may be assessed in light of the efforts made to contact a parent and the time it took to reach one.
- A delay in parent notification, standing alone, does not necessarily require suppression of a confession that occurred before or apart from any proven statutory violation tied to the taking of the statement.

## Conclusion

The court of appeals affirmed J.B.J.’s adjudication of delinquency, holding that his schoolhouse confession was admissible because it was not established as a custodial “statement of a child” governed by the Family Code’s formal statement procedures and because the post-custody parental-notification timeline—given ongoing efforts and notice to the father about ninety minutes after custody—did not require suppression.


In the Matter of J.B.J., 86 S.W.3d 810 (2002)