In the Matter of R. J. H.

The majority today creates a new standard for the admission of a noncustodial statement made by a juvenile. Because I believe the record supports the trial court’s conclusion that the oral statements made by appellant several days after the crime were not the product of custodial interrogation and are voluntary and admissible, I respectfully dissent. Appellant does not assert that he was in custody at the time he made the oral statements; rather, because the initial written statement was inadmissible under the Family Code, he contends that the subsequent oral statements were tainted. The…