Justices: No Miranda violation in school delinquency case

 A 17-year-old boy adjudicated delinquent for spray painting sexual graffiti on bathroom walls at Brownsburg High School was not required to be read his Miranda rights because he was only interviewed by a school official, not by police, the Indiana Supreme Court ruled.

In March 2017, D.Z. was seen on surveillance footage vandalizing a bathroom in his school. Assistant Principal Demetrius Dowler called D.Z. into his office for a closed-door discussion. With just the two of them in the room the boy admitted to the crime and was suspended for five days. Dowler confided about D.Z.’s confession with school resource officer Nathan Flynn, who then spoke with D.Z. about the incident. After confessing again, Flynn told the boy he would be charged. 

On appeal, D.Z. argued the admission of his statement to Dowler, as well as photos pulled from surveillance footage, photos of the graffiti and evidence supporting the adjudication, should have been suppressed because he had not been advised of his rights. D.Z. was adjudicated for what would be criminal mischief if committed by an adult.

The Indiana Supreme Court affirmed the adjudication in D.Z. v. State of Indiana, 18S-JV-295, finding that the juvenile court correctly denied D.Z.’s motion to suppress his incriminating statements to Assistant Principal Dowler because he was not under custodial interrogation.

“While Dowler did share D.Z.’s confession with Officer Flynn, the focus was not on criminal charges but on finding out who was doing the graffiti,” Chief Justice Loretta Rush wrote Wednesday. “Nor does Officer Flynn’s interview with D.Z. show an agency relationship simply because it came on the heels of Dowler’s interview.”

The court concluded D.Z. was not entitled to Miranda rights since he was interviewed only by a school official and not the police. The court also concluded sufficient evidence supported the adjudication.

A divided panel of the Indiana Court of Appeals previously reversed D.Z.’s adjudication, with each of three judges writing separately. The court aligned with the dissent of COA Judge Elaine Brown, who found no Miranda violation.