## Facts

- Aaron, an 11-year-old boy, was indicted for murdering Stephen Conelly, a two-year-old, by throwing Conelly into a well.
- The well’s sides were described as likely too high for the two-year-old to climb out without help.
- Aaron was seen playing with Conelly shortly before Conelly went missing.
- During the search, Aaron told searchers that Conelly had walked off down the road.
- After Conelly’s body was removed from the well, Aaron claimed he had seen Conelly fall in.
- The coroner and the jury questioned Aaron, and he denied involvement.
- When the jury visited the well, Aaron’s master and a juror took Aaron aside and spoke to him about telling the truth.
- Witnesses reported that the master and juror told Aaron it was best to tell the truth; Aaron later testified they also said “the devil would get him” if he lied and that if he told the truth he would not go to jail.
- After that exchange, Aaron admitted that he lifted Conelly up and over into the well, and he also admitted seeing the body removed.
- Aaron was jailed and repeated his confession many times over the next month.
- At trial, Aaron recanted and testified that he confessed because of what his master and the juror told him.
- Defense counsel objected to admitting the confessions, arguing (among other grounds) that Aaron’s youth made the statements incompetent evidence and that the statements were not voluntary because they were induced by threats and promises.
- The trial court admitted the confessions, the jury convicted Aaron of murder, and the defense moved for a new trial; the matter was presented to the Supreme Court of New Jersey for its opinion.

## Issues

1. Whether Aaron’s confessions were admissible when made after a juror and his master urged him to confess with statements that could be understood as a threat (spiritual punishment) and a promise (avoiding jail).
2. Whether later, repeated confessions made while Aaron was jailed were admissible if the initial confession was made under an improper inducement.
3. Whether, given Aaron’s age and the circumstances in which the admissions were obtained, the conviction could stand or a new trial should be granted.

## Decision

- The Supreme Court of New Jersey ordered a new trial.
- The court concluded that the confessions should not have been admitted because the circumstances indicated they were not the product of a free and voluntary choice, particularly for a child confronted by authority figures.
- The court treated the later repeated confessions as affected by the same influence unless the State could show the earlier inducement had been removed.

## Legal Principles

- A confession is inadmissible if it is obtained by threats or by promises of benefit made by persons in authority, because such inducements can produce unreliable statements.
- Threats of spiritual harm and promises of temporal advantage can each operate as improper inducements, especially when directed at a child.
- When an initial confession is obtained through an improper inducement, later confessions are generally regarded as tainted by the same influence unless the prosecution shows the inducement was dispelled and the later statement was truly voluntary.
- Courts must use special care in assessing the voluntariness and reliability of a child’s confession, given a child’s susceptibility to pressure from adults and authority figures.

## Conclusion

State v. Aaron set aside a murder conviction and granted a new trial where the State’s case depended heavily on admissions made by an 11-year-old after statements by his master and a juror that could be understood as both a threat and a promise; the court held that, in those circumstances, the confessions (including later repetitions in jail) were not shown to be voluntary enough to support the verdict.


State v. Aaron, 4 N.J.L. 269 (1818)