Commonwealth v. Williams

One evening, store manager James Duggan was robbed of a bag containing his business’s funds as he was heading to a bank to deposit the funds. Several bystanders witnessed the scene, and Eric Williams (defendant) was identified as one of the robbers. Eric, aged 17 and a half, had been adjudicated as a juvenile delinquent at least four prior times, had been committed to a youth detention facility on three previous occasions, and was then on probation. Detectives arrested Eric and took him to the police station. Officers informed Eric why he had been arrested and asked where his parents were. Eric responded that his father was at home. Detectives made contact with Ollie Williams, Eric’s father, and informed Ollie of the circumstances. Back at the station, Ollie consulted briefly with Eric in private. In the presence of both Eric and Ollie, officers advised Eric of his Miranda rights. Eric was asked whether he understood each of his rights—e.g., whether he understood that he had a right to an attorney—and each time, Eric responded affirmatively. With Ollie still present, Eric waived his Miranda rights and made an incriminating statement. Both Eric and Ollie signed Eric’s confession. The state (plaintiff) brought charges against Eric. Before trial, Eric filed a motion to suppress his confession. The trial court granted the motion because Eric had had no opportunity to privately consult with Ollie after they were both informed of Eric’s constitutional rights. An intermediate court reversed, concluding that Eric had waived his rights, the waiver was knowing, and Eric’s confession was voluntary. Eric appealed.