Arrest of a Juvenile Following His Confession
In Ramirez v. State, 739 So. 2d 568 (Fla. 1999), a juvenile offender was implicated in a murder by an associate, Grimshaw. See id. at 572.
Grimshaw placed a sheriff-monitored phone call to Ramirez during which items of physical evidence related to the crime were discussed. See id.
Subsequently, Ramirez, who was seventeen at the time, was visited at home by a sheriff's deputy and turned over evidence relating to the crime. See id.
Ramirez also took the deputy to retrieve other items and agreed to accompany the deputy to the station for questioning. See id.
At the station, Ramirez was interrogated and eventually admitted to breaking into the victim's house. See id. Subsequent to his admission and prior to any Miranda warning, a detective stated:
Why don't you let Nate Ramirez know about his rights.
I mean, he's already told us about going in the house and whatever.
I don't think that's going to change Nate's desire to cooperate with us. Id.
At this point, Ramirez asked if he was being placed under arrest and the detective responded, "No, no, I'm just reading your rights at this time." Id.
Later, Ramirez admitted his involvement in the murder and after he had fully confessed, the detectives obtained a written waiver of his Miranda rights. Id.
In Ramirez, the court concluded that the defendant's statement should have been suppressed. See id. at 578.
In so holding, we stressed that Ramirez was never told he was free to leave, that he was a juvenile (just turning seventeen), and that the detectives exploited his prior unwarned statements in an effort to downplay the significance of the Miranda warnings when they suggested that the warnings would not change Ramirez's desire to cooperate. See id. at 574, 576.
Additionally, we noted that when the detectives responded negatively to Ramirez's question pertaining to whether he was under arrest,Ramirez had already implicated himself in the crime and the detectives had independent corroboration of his involvement and ample probable cause to arrest him for murder, . . . and that it was simply inappropriate for the police to make a representation intended to lull a young defendant into a false sense of security and calculated to delude him as to his true position at the very moment that the Miranda warnings were about to be administered. Id. at 576-77.