People v. Patterson

NJDC joined the Center on Wrongful Convictions of Youth, the Exoneration Project at University of Chicago Law School, and several other interested organizations in filing an amicus brief in the Illinois Supreme Court. Amici urged the court to uphold the Illinois Appellate Court decision overturning the trial court’s conviction of 15-year-old Ronald Patterson and suppressing his confession as involuntary. The Illinois Supreme Court granted the State’s discretionary motion for leave to appeal.

This case centers around 15-year-old Ronald, who reads at a second grade level and has an IQ of about 72, and on the low end of the category of borderline intellectual functioning. After an unrecorded late-night police interrogation, he confessed to sexually assaulting a woman in her early 20’s who worked at the group home where Ronald lived. Ronald testified that the older woman actually assaulted him and outside of his confession, has maintained his innocence. Although Illinois statute requires that a law enforcement officer who arrests a minor immediately make a reasonable attempt to notify the parent or other person legally responsible for the minor’s care, the police made only perfunctory efforts to contact a concerned adult—leaving voicemail messages on office phone numbers of the director of the group home, and that of Ronald’s caseworker—and began interrogation immediately after leaving those messages. The confession became the cornerstone of the prosecution of Ronald in adult criminal court and led to his incarceration.

In the brief, amici provided an extensive review of the special care required when police interrogate a youth, due to the unique susceptibility of juveniles to involuntary and false confessions. Amici noted that this susceptibility is heightened when a youth also deals with mental illness, cognitive impairments, or other developmental challenges. The brief discusses the problems with various police interrogation tactics that are known to induce false confessions, the Supreme Court and Illinois case law surrounding these issues, and the Illinois legislature’s requirement that certain custodial interrogations be electronically recorded. Notably, just two months before Ronald’s interrogation, Illinois expanded its law on electronic recording. Under that law, Ronald’s interrogation would have been required to be recorded. Amici addressed the inability of a “youth officer” to act as an interested adult for the youth. Amici also highlighted persuasive international rules and judgments that provide broad protections to ensure a minor has access to counsel during—or at least prior to—police interrogation.

Court: Illinois Supreme Court
Filed:
October 11, 2013 
Amicus Brief Discusses: Custodial Statements, Police Interrogation

Oral Argument: Pending
Decision
: Pending