Arizona v. Tyler B.

In March 2013, NJDC, along with 40 other organizations and individuals, signed onto an amicus brief filed by Juvenile Law Center in support of Tyler B., asserting that the trial court properly exercised its discretion in granting Tyler’s motion to suppress evidence derived from a blood draw. Amici argued that a youth’s age and other attributes of being a juvenile are relevant and must be considered in assessing the voluntariness of consent. In support of this argument, amici cited to U.S. Supreme Court jurisprudence, including the Court’s ruling in J.D.B. v. North Carolina, and the social science adopted by the Court in J.D.B. and other cases, which accept that youth are different from adults when assessing the voluntariness of their confessions. Amici also argued that students are particularly susceptible to coercion during police encounters in schools.

This case revolved around the voluntariness of a juvenile’s consent to a blood draw taken during an interrogation in a school setting. Tyler B., a 16 year old special education student, was arrested for DUI, handcuffed, interrogated by school personnel and law enforcement, and eventually subjected to a blood draw while being held at school. Tyler initially refused consent, but after being held for two hours behind closed doors with two law enforcement officers and three school personnel, he relented and allowed them to draw blood. During that time he was denied access to his parents. Tyler’s parents were notified that there was an issue with their son, but were not told he was under arrest and being interrogated. They came to the school but were left sitting in the hallway and Tyler was not told they were present. The trial court suppressed the evidence derived from the blood draw but the Court of Appeals reversed. The Arizona Supreme Court granted review.

On May 30, 2013, in an important win, the Supreme Court of Arizona held that a youth’s age and the presence or absence of parents must be considered in determining whether a youth consented to a search. Specifically, the Court held that 16 year-old Tyler B. did not consent to the blood draw at issue.

Court: Supreme Court of Arizona
Filed:
March 15, 2013 (download .pdf)
Amicus Brief Discusses: Adolescent Development; School Interrogation; Search & Seizure

Oral Argument: March 26, 2013
Decision
: May 30, 2013 (download .pdf)