## Facts

- A 16-year-old suspect was arrested late at night in Long Beach, California, in connection with a fatal shooting during an attempted bicycle robbery.
- Police executed arrest and search warrants around 11:30 p.m., took the juvenile to the station in handcuffs, and placed him alone in an interrogation room.
- Two detectives interrogated him after midnight for more than three hours; the first portion was unrecorded and occurred without a parent or lawyer present and without food or breaks.
- The juvenile testified that during the unrecorded questioning he repeatedly asked for his mother and for an attorney, but the detectives continued questioning.
- He also testified that detectives used threats and implied promises of leniency (including demonstrations suggesting he would face life imprisonment unless he cooperated).
- After approximately two-and-a-half hours of denials, detectives began recording, administered Miranda warnings, obtained a recorded waiver, and took an 11-minute confession.
- After the confession, the juvenile contacted his attorney and promptly reported that he had requested counsel earlier and that threats and promises were used; the attorney later testified consistently at the suppression hearing.
- The prosecution relied primarily on one detective’s account of the unrecorded period; his testimony was equivocal and he could not clearly recall whether counsel was requested or whether threats were made.

## Issues

1. Whether the interrogation violated Miranda and Edwards because the juvenile invoked the right to counsel during the unrecorded portion and questioning did not cease.
2. Whether the confession was involuntary under the Due Process Clause based on the totality of the circumstances, including age, late-night isolation, and coercive tactics.
3. Whether the state courts’ rejection of the defense account amounted to an unreasonable determination of the facts under 28 U.S.C. § 2254(d)(2).
4. Whether admission of the confession was harmless on federal habeas review.

## Decision

- The Ninth Circuit reversed the district court’s denial of habeas relief and remanded for appropriate relief.
- The court held that the state courts’ material fact determinations concerning invocation of counsel and voluntariness were unreasonable under AEDPA.
- Crediting the only reasonable view of the record, the court concluded the juvenile invoked counsel, police continued interrogation in violation of Miranda/Edwards, and the later recorded waiver did not cure the violation.
- The court independently held the confession involuntary under due process given the late-night custodial setting, youth, absence of a parent or attorney, length of questioning, and threats/implied promises.
- The court found the constitutional error not harmless because the prosecution’s case depended heavily on the confession and remaining evidence was weak.

## Legal Principles

- Under AEDPA, a federal court may grant habeas relief when the state court’s decision rests on an unreasonable determination of the facts in light of the evidence presented.  
- A state court’s fact-finding may be unreasonable when it disregards or irrationally discounts contemporaneous, corroborated evidence and relies on equivocal or internally inconsistent testimony.
- Under Edwards, once a suspect in custody invokes the right to counsel, interrogation must cease until counsel is provided unless the suspect initiates further communication.
- A Miranda waiver obtained after police ignore an earlier request for counsel does not validate statements produced by continued interrogation.
- A confession is involuntary under the Due Process Clause if, under the totality of the circumstances, police pressure overbears the suspect’s will; youth, isolation, late-night interrogation, absence of supportive adults, and threats or promises weigh heavily in that analysis.
- On federal habeas review, admission of an unlawfully obtained confession warrants relief if it had a substantial and injurious effect on the verdict.

## Conclusion

The Ninth Circuit granted habeas relief because the state courts unreasonably determined key interrogation facts under AEDPA, and because the juvenile’s confession was obtained after an ignored request for counsel and through coercive circumstances rendering it inadmissible; given the weakness of other evidence, the error was not harmless.


Taylor v. Maddox, 366 F.3d 992 (9th Cir. 2004)