Smith v. State

BERGER, Justice:

In this appeal, we consider whether a statement given to the police by a mildly mentally retarded juvenile was admissible at his delinquency trial. After viewing a portion of the videotaped statement and hearing testimony from the police officer and others, the Family Court concluded that the juvenile knowingly and voluntarily waived his Miranda rights. On review, we adhere to the totality of the circumstances test, but we consider the juvenile’s mental limitations and the fact that his mother was not with him during the interview as significant factors. Having viewed the…