Shelton v. State
In Shelton v. State, 287 Ark. 322, 699 S.W.2d 728 (1985), a police officer had been brutally murdered by Shelton's accomplice, Porier. Shelton, age seventeen, and another accomplice, age fourteen, had been haled out of a bunkhouse by officers at 2:30 a.m. by use of a P.A. system. The boys were told that the officers were looking for Porier and another suspect in the killing, and they were driven in a patrol unit to the home of Shelton's parents.
When they arrived at the home, Shelton was left alone in the vehicle with a police officer who stressed the seriousness of the crime and told Shelton that he had better tell if he knew the location of the suspects or anything about the murder. Shelton then began crying and said, "We did it. We did it. We were there. We were there."
Shelton was then administered Miranda warnings and was taken to the police station where he gave a detailed statement after again being advised of his rights. Focusing on Shelton's age and the place of interrogation, the supreme court determined that Shelton's initial statement was the product of custodial interrogation, and it reversed the trial court's denial of the motion to suppress.
The court also held that the subsequent statement given at the police station should also have been excluded.
In so holding, the court discussed the rule in Oregon v. Elstad and found it inapplicable because of the coercive elements present at the time the initial admission was made.