People v. Claxton – Case Brief Summary (California)

In People v. Claxton (1982) 129 Cal.App.3d 638, a juvenile defendant was in custody in juvenile hall. The defendant walked into an office, acknowledged the group supervisor, and asked him, "'"How is it going, Mr. Huston?"'" Huston answered, "'"Fine,"'" then continued, "'"What did you get yourself into?"'" (Id. at p. 647.) The defendant responded by describing his criminal conduct in narrative form, and Huston interjected questions for the purpose of clarifying some points. (Id. at pp. 647-648.)

The Claxton court found that Huston's neutral inquiries to the defendant's volunteered statements did not constitute an interrogation under Rhode Island: "We do not perceive the neutral inquiry, 'What did you get yourself into?' as words that Huston 'should have known were reasonably likely to elicit an incriminating response.'

In the patois of the streets or jailhouse, the inquiry is tantamount to 'What's up?' or 'What are you in for?' The question did not require an inculpatory reply, nor does anything in the record suggest that Huston expected one.

The defendant, if he had desired not to talk, could have countered Huston's 'offhand' remark with any one of a number of rejoinders, from a laconic 'trouble' to a recitation of the charges against him, or the alternative, a disclaimer such as he twice gave to the police.

He chose instead, for his own reasons, to make a full confession." (Claxton, supra, at pp. 654-655.)