## Facts

- J.M.A., a juvenile, was placed by the state in a licensed, compensated foster home with Mr. and Mrs. Blankenship.
- Mrs. Blankenship suspected J.M.A. was involved with drugs after seeing unfamiliar children briefly visit the home.
- She periodically searched J.M.A.’s room and listened to a phone call in which he said he was nearly out of marijuana and needed more pills.
- Mrs. Blankenship found a pipe in his room and later found a bag of marijuana in a jacket pocket.
- She contacted J.M.A.’s social worker, who came to the home with a plain-clothes police officer.
- In an in-home confrontation, J.M.A. admitted the jacket was his but denied knowledge of the marijuana; he was not given Miranda warnings.
- J.M.A. was taken to juvenile detention, adjudicated delinquent, and committed for an indeterminate term up to age nineteen.

## Issues

1. Whether a state-licensed and compensated foster parent is a state agent such that her searches and monitoring of a foster child constitute governmental action subject to constitutional search-and-seizure limits.
2. If the foster parent is a state actor, whether her room searches and telephone eavesdropping were unreasonable searches requiring suppression.
3. Whether statements obtained during the in-home confrontation with a social worker and police officer, without Miranda warnings, were inadmissible in the delinquency proceeding.

## Decision

- The Alaska Supreme Court affirmed the delinquency adjudication and denial of the motion to suppress.
- The court held Mrs. Blankenship was not acting as a state agent; her searches and eavesdropping were private conduct, not governmental action.
- Because the conduct was private, constitutional search-and-seizure restrictions did not apply, and the pipe and marijuana evidence was admissible.
- The court held the in-home confrontation did not constitute custodial interrogation requiring Miranda warnings under the circumstances; J.M.A.’s statements were admissible.

## Legal Principles

- Constitutional search-and-seizure protections generally restrict governmental conduct; evidence obtained through independent private action is not suppressed on Fourth Amendment/state constitutional grounds absent state instigation or direction.
- A foster parent’s licensing, compensation, and state placement of a child do not alone convert the foster parent’s supervisory acts into state action for search-and-seizure purposes.
- Miranda warnings are required only for custodial interrogation; an informal, home-based meeting involving a social worker and a plain-clothes officer may fall outside Miranda when the juvenile is not in custody or significantly restrained.

## Conclusion

The court upheld admission of drug evidence found by a foster parent and statements made during an in-home confrontation, concluding the foster parent was not a state agent and the circumstances did not amount to custodial interrogation requiring Miranda warnings.


J.M.A. v. State, 542 P.2d 170 (Alaska 1975)