## Facts

- S.C. was a 15-year-old suspected of burglarizing a residence after a witness identified him as the likely burglar.
- A police officer went to S.C.’s home and spoke with S.C.’s mother, who stated that S.C. was not home.
- The officer located S.C. down the street, questioned him, and returned with him to the home.
- The officer questioned S.C. again about the burglary in his mother’s presence; S.C. became fidgety and nervous.
- Other officers arrived, and officers placed S.C. in handcuffs.
- Two officers told S.C. he was being detained but was not under arrest, and they placed him in a patrol car.
- The officer asked S.C.’s mother for consent to enter the home; she refused numerous times.
- An officer then told S.C. that if he did not return the property and it was later found in the house, the owner of the house could be arrested.
- S.C. then stated the property was inside, agreed to show the officer, and led officers into the home.
- S.C.’s mother did not voice another objection at the moment the officers entered with S.C.
- Inside, S.C. pointed out some of the suspected stolen property.
- S.C. was not arrested at the scene, but the State later filed a juvenile petition alleging delinquent conduct equivalent to burglary.
- S.C. moved to suppress the evidence obtained after entry into the home; the trial court denied the motion.
- S.C. pleaded guilty and appealed, challenging the denial of his motion to suppress.

## Issues

1. Whether officers may lawfully enter a home without a warrant based on a detained juvenile’s purported consent after a co-occupant parent repeatedly refused consent to entry.
2. Whether S.C.’s consent and related statements were voluntary under the totality of the circumstances, including his age, handcuffing, patrol-car detention, and the officer’s statement that the homeowner could be arrested.
3. If the entry was unconstitutional, whether the recovered property and S.C.’s statements had to be suppressed as fruits of the unlawful entry.

## Decision

- The appellate court reversed the trial court’s denial of S.C.’s motion to suppress.
- The court held the State did not meet its burden to show a valid exception to the warrant requirement justified the officers’ entry into the home.
- The court concluded the officers could not rely on S.C.’s purported consent to enter where his mother—an adult co-occupant—had expressly refused consent multiple times while present.
- The court further determined that, given the circumstances of S.C.’s detention and the warning that the homeowner could be arrested, the State failed to show S.C.’s consent was the product of free and voluntary choice rather than coercion.
- The court remanded for further proceedings consistent with its suppression ruling.

## Legal Principles

- A warrantless entry into a home is presumptively unreasonable under the Fourth Amendment unless the State proves a recognized exception, such as voluntary consent.
- The State bears the burden to prove consent was freely and voluntarily given under the totality of the circumstances.
- Voluntariness analysis may consider a juvenile’s age, restraint (including handcuffs), the setting of the encounter (including patrol-car detention), and whether police statements amount to coercion or implied threats.
- When a physically present co-occupant expressly refuses consent, officers generally may not justify entry by obtaining consent from another occupant in a way that overrides that refusal.
- Evidence obtained as a result of an unconstitutional home entry, including physical items found inside and statements tied to the entry, is subject to exclusion unless an exception applies.

## Conclusion

In the Matter of S.C. held that officers could not validate a warrantless entry into a home by relying on a detained 15-year-old’s purported consent after his mother repeatedly refused consent, and that the circumstances surrounding the detention and the officer’s warning about arresting the homeowner did not support a finding of voluntary consent; accordingly, the appellate court reversed the denial of suppression and remanded.


In the Matter of S.C., 523 S.W.3d 279 (2017)