State v. John Doe

IN THE COURT OF APPEALS OF THE STATE OF IDAHO

Docket No. 51081

In the Interest of: John Doe (2023-33), )
Juvenile Under Eighteen (18) Years of ) Filed: October 7, 2025
Age. )
------------------------------------------------- ) Melanie Gagnepain, Clerk
STATE OF IDAHO, )
)
Petitioner-Respondent, )
)
v. )
)
JOHN DOE (2023-33), )
)
Juvenile-Appellant. )

Appeal from the District Court of the Fourth Judicial District, State of Idaho, Ada
County. Hon. Gerald F. Schroeder, District Judge. Hon. Cathleen MacGregor Irby,
Magistrate.

Decision of the district court, on intermediate appeal from the magistrate court,
affirming the order and decision regarding purview under the Juvenile Corrections
Act, affirmed.

Erik R. Lehtinen, State Appellate Public Defender; Andrea W. Reynolds, Deputy
Appellate Public Defender, Boise, for appellant.

Hon. Raúl R. Labrador, Attorney General; Kenneth K. Jorgensen, Deputy Attorney
General, Boise, for respondent.
________________________________________________
TRIBE, Judge
John Doe appeals (2023-33) from the district court’s decision, on intermediate appeal from
the magistrate court, affirming the order and decision, finding that Doe was under the purview of
the Juvenile Corrections Act (JCA). We affirm.

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I.
FACTUAL AND PROCEDURAL BACKGROUND
Doe, fifteen-years-old at the time, was accused of inappropriate sexual conduct by L.K.,
his thirteen-year-old half-sister. After L.K. participated in a CARES1 interview, Ada County
Detective, Jessica Johnson, contacted Doe’s mother to schedule an interview with Doe. Doe’s
stepfather drove Doe to the sheriff’s office for the interview. Notably, the magistrate court
described Doe’s relationship with his stepfather as “very strained” and also acknowledged the
allegations of physical abuse Doe had made against his stepfather.
When Doe and his stepfather arrived at the sheriff’s office, Detective Johnson escorted Doe
and his stepfather to a “soft room.” Detective Johnson later explained that the “soft room” is
designed like a living room with a couch, a love seat, an ottoman, a lamp, and a television set.
Unlike an interrogation room, a soft room cannot be locked from the outside. Just like other
interview rooms, civilians cannot access the “soft room” without staff or law enforcement.
At the beginning of the interview, Doe’s stepfather was present in the room. About a
minute and a half into the interview, Detective Johnson told Doe: (1) he was not under arrest
(2) the door to the room, although closed for privacy, was unlocked; (3) unless Doe murdered
someone, he would be going home with his stepfather; and (4) everything Doe said would be
included in the report that is available to the “prosecutors and judges.” The detective then
explained that, in the beginning of the conversation she would get to know Doe but later they
would talk about “stuff that might be kind of embarrassing” and “things that [Doe would not] want
[his] dad to really hear.” Detective Johnson told Doe that the conversation would involve behavior
that is not “correct.” The detective reiterated that she knew what Doe did and the purpose of the
conversation was to discover Doe’s reasons for his inappropriate behavior and provide him with
help.
Detective Johnson asked if Doe wanted his stepfather in the room. Doe responded that he
did not, and the detective had Doe’s stepfather escorted out of the soft room. At that time, the
detective told Doe that he should notify her if he did not want to talk to her anymore or if he felt
like he needed support so she could let Doe’s stepfather back into the room.

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Children at Risk Evaluation Service (CARES).

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Detective Johnson’s interview with Doe lasted approximately two hours beginning with
casual conversation. The detective did not read Doe his Miranda2 rights. During the interview,
the detective indicated that she was aware that Doe acted inappropriately toward his sister, and the
purpose of the interview was to help Doe address his actions. When Doe denied the allegations,
Detective Johnson asserted that Doe was not being truthful. In response to Detective Johnson’s
warning that a polygraph examination would expose any dishonesty, Doe stated that he understood
polygraph results were not admissible in court.
Detective Johnson did not explicitly inform Doe of his right to leave or to refuse to answer
questions. However, she advised Doe that the door to the “soft room” (where the interview
occurred) was closed for privacy but not locked. Immediately after Doe requested an attorney, the
detective terminated the interview. Detective Johnson then left Doe alone in the room for
approximately eighteen minutes, closing the door upon her exit. She later returned with Doe’s
stepfather. Before concluding the interview, Detective Johnson said that she was sorry Doe had
not told her the truth about his conduct.
Ultimately, Doe was charged with two counts of lewd and lascivious conduct with a minor
(Idaho Code § 18-1508). Doe filed a motion to suppress the statements he made during the
interview because the detective failed to provide Miranda warnings to him. The magistrate court
denied Doe’s motion to suppress, concluding he was not in custody for purposes of Miranda and
the statements he made were voluntary. After an evidentiary hearing, the magistrate court issued
a written memorandum decision, finding Doe under the purview of the JCA. The magistrate court
then set the matter for a disposition hearing. Doe filed a timely notice of an intermediate appeal
to the district court. The district court concluded that the magistrate court erred in finding Doe
guilty of count I and vacated the magistrate court’s finding on count I. The district court affirmed
the magistrate court’s denial of Doe’s motion to suppress and determined that Doe was within the
purview of the JCA based on count II. Doe again appeals.

2
See Miranda v. Arizona, 384 U.S. 436 (1966).

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II.
STANDARD OF REVIEW
For an appeal from the district court, sitting in its appellate capacity over a case from
the magistrate court, we review the record to determine whether there is substantial and competent
evidence to support the magistrate court’s findings of fact and whether the magistrate court’s
conclusions of law follow from those findings. Pelayo v. Pelayo, 154 Idaho 855, 858-59, 303 P.3d
214, 217-18 (2013). However, as a matter of appellate procedure, our disposition of the appeal
will affirm or reverse the decision of the district court. Id. Thus, we review the magistrate court’s
findings and conclusions, whether the district court affirmed or reversed the magistrate court and
the basis therefor, and either affirm or reverse the district court.
III.
ANALYSIS
Doe argues that the district court erred by affirming the magistrate court’s order denying
Doe’s motion to suppress statements he made during his interview with Detective Johnson because
he was subjected to a custodial interrogation without Miranda warnings. Doe contends that, under
the totality of the circumstances, a reasonable fifteen-year-old in Doe’s position would not have
believed that he was allowed to terminate the interview and leave.
The requirement for Miranda warnings is triggered by custodial interrogation. State v.
Medrano, 123 Idaho 114, 117, 844 P.2d 1364, 1367 (Ct. App. 1992). The United States Supreme
Court defines custody as a situation where a suspect’s freedom of action is curtailed to a degree
associated with formal arrest. Berkemer v. McCarty, 468 U.S. 420, 440 (1984). The initial
determination of custody depends on the objective circumstances of the interrogation, not on the
subjective views harbored by either the interrogating officers or the person being questioned.
Stansbury v. California, 511 U.S. 318, 323 (1994). To determine if a suspect is in custody, the
only relevant inquiry is how a reasonable person in the suspect’s position would have understood
his or her situation. Berkemer, 468 U.S. at 442; State v. Myers, 118 Idaho 608, 611, 798 P.2d 453,
456 (Ct. App. 1990).
A court must consider all of the circumstances surrounding the interrogation. Stansbury,
511 U.S. at 322; State v. James, 148 Idaho 574, 577, 225 P.3d 1169, 1172 (2010). Factors to be
considered may include the degree of restraint on the person’s freedom of movement (including

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whether the person is placed in handcuffs), whether the subject is informed that the detention is
more than temporary, the location and visibility of the interrogation, whether other individuals
were present, the number of questions asked, the duration of the interrogation or detention, the
time of the interrogation, the number of officers present, the number of officers involved in the
interrogation, the conduct of the officers, and the nature and manner of questioning. See Berkemer,
468 U.S. at 441-42; James, 148 Idaho at 577-78, 225 P.3d at 1172-73. The burden of showing
custody rests on the defendant seeking to exclude evidence based on a failure to administer
Miranda warnings. James, 148 Idaho at 577, 225 P.3d at 1172.
When, as here, the suspect is a minor, and law enforcement is aware of this fact, courts
apply this same standard but must also consider factors specific to juveniles such as the child’s
age, maturity, experience with law enforcement, and whether a parent or supportive adult was
present. J.D.B. v. North Carolina, 564 U.S. 261, 274 (2011); State v. Doe, 130 Idaho 811, 818,
948 P.2d 166, 173 (Ct. App. 1997). However, no single factor is dispositive. See State v. Godwin,
164 Idaho 903, 916-17, 436 P.3d 1252, 1265-66 (2019). The ultimate question is whether a
reasonable person in the minor’s position would believe their freedom was significantly restricted.
See id.; Doe, 130 Idaho at 818, 948 P.2d at 173. Both Doe and the State rely on various factors to
support their respective positions. Accordingly, we examine these factors to determine whether
Doe met his burden of proving he was in custody.
First, a juvenile’s access to a parent or other supportive adult is a factor evaluated when
determining the custodial status for Miranda purposes. Doe, 130 Idaho at 817, 948 P.2d at 172.
Doe argues that, although his stepfather transported Doe to the sheriff’s office and was present at
the outset of the interview, the stepfather’s alleged abusive history toward Doe rendered his
stepfather unsupportive. The supportive adult factor is most relevant in situations in which a
juvenile has demonstrated trouble understanding his or her predicament or law enforcement
prevents a supportive adult from speaking with the juvenile. In this case, Detective Johnson did
not prevent Doe from accessing his stepfather. The opposite is true. After Detective Johnson
explained the purpose of the interview, she asked whether Doe wanted his stepfather to remain.
Doe declined, stating he would not feel comfortable discussing the matter in his stepfather’s
presence. The stepfather then provided Detective Johnson with his phone number so she could
contact him at any time. Detective Johnson assured Doe if he did not want to continue the

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interview she would contact his stepfather. Shortly after Doe terminated the interview, and
Detective Johnson contacted the stepfather, he returned to the sheriff’s department. Nothing in the
record indicates that Doe’s access to his stepfather (or to another adult that Doe would have
considered more supportive) was obstructed. In addition, Doe displayed a sophisticated
understanding of the legal process; first, by noting that polygraph results are inadmissible in court
and, later, by invoking his right to counsel to terminate the interview. Accordingly, we conclude
that Doe had unimpeded access to his stepfather regardless of whether Doe chose to seek his advice
based on their alleged strained relationship.
Second, the fact that questioning takes place in a police station does not necessarily mean
that a party is in custody. State v. Osborne, 130 Idaho 365, 370, 941 P.2d 337, 342 (Ct. App.
1997). The interview took place at the Ada County Sheriff’s Office in the “soft room” during its
regular business hours. The “soft room” is one of five rooms designated for interviews and
interrogations. All these rooms are equipped with video-recording systems. Most notably, the
soft room, unlike the other interview rooms, cannot be locked from the outside. Detective Johnson
took Doe and his stepfather to the soft room for the interview. Doe presented no evidence that
there were barriers preventing him from leaving the soft room if he chose to do so. The remaining
factors, including the time of day when the interview took place, the unlocked door to the interview
room, the lack of security doors on the way to the soft room, and the environment in the interview
room suggest that a reasonable person of Doe’s age and under these circumstances would have felt
free to terminate the encounter and leave the building, as Doe eventually did.
Third, a video recording of the interview shows it lasted approximately two hours. This
factor is not determinative and depends on the surrounding factors. See Yarborough v. Alvarado,
541 U.S. 652, 665 (2004) (finding length of interview was a factor to consider when determining
custodial interrogation); see also Howes v. Fields, 565 U.S. 499, 515-17 (2012) (finding of no
custody even though the defendant was questioned for five to seven hours without Miranda
warnings). In this case, the length of the interview does not weigh in favor of finding custody.
Fourth, there is no dispute that the only officer present throughout the entirety of Doe’s
interview was Detective Johnson. Although the detective was armed, she wore plain clothes and
did not use her gun to intimidate Doe. The presence of a single, plain clothes officer during
questioning does not weigh in favor of finding custody.

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Fifth, Doe argues that the detective’s questioning was accusatory and weighs heavily in
favor of finding custodial interrogation. From the beginning of the interview, Detective Johnson
stated that she knew what Doe did, that Doe’s behavior was inappropriate, and the only reason she
was meeting with Doe was to provide him with the “help” he needed. Shortly after Doe’s
stepfather left the soft room, the detective again stated that she knew what Doe did to L.K.
Detective Johnson repeated this accusation several times in the span of a few minutes. Detective
Johnson stated that she was very experienced and the information L.K. disclosed was very detailed,
which indicated that L.K. was truthful. Nearly every question thereafter was accusatory. Detective
Johnson informed Doe that his statements would be included in a report available for the
prosecutor’s review. The magistrate court made a clearly erroneous finding that, although
Detective Johnson knew about inappropriate conduct between Doe and L.K. from the CARES
interview, the detective “had no opinions as to [Doe’s] involvement.” Detective Johnson’s
interview of Doe was accusatory.
Lastly, in cases involving a juvenile, the juvenile suspect’s age may be analyzed as part of
the court’s determination of whether a custodial interrogation occurred. Doe, 130 Idaho at 818,
948 P.2d at 173. The United States Supreme Court stated that “a child’s age properly informs the
Miranda custody analysis” since “a reasonable child subjected to police questioning will
sometimes feel pressured to submit when a reasonable adult would feel free to go.” J.D.B., 564
U.S. at 272. Here, the district court described Doe as a fifteen-year-old of average or
above-average intelligence. Despite his age, Doe had experience and knowledge of the justice
system as evidenced by his statement that results of a polygraph test were not admissible in court
proceedings. Doe appeared at ease during the interview with Detective Johnson. In fact, Doe was
more comfortable talking to the detective alone rather than with his stepfather in the room.
Notably, Doe did not just request to stop the interview, he instead requested an attorney.
Under the totality of the circumstances, a reasonable fifteen-year-old of Doe’s maturity and
in his position would have felt free to terminate the interview and leave. The district court did not
err in affirming the magistrate court’s order denying Doe’s motion to suppress statements made
during his interview based on the detective’s failure to give Miranda warnings.

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IV.
CONCLUSION
The district court correctly affirmed the magistrate court’s order denying Doe’s motion to
suppress. Accordingly, the decision of the district court, on intermediate appeal from the
magistrate court, affirming the order and decision regarding purview under the JCA is affirmed.
Judge LORELLO and Judge Pro Tem MELANSON, CONCUR.

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