In the Matter of J.J.D.L., 189 N.C. App. 777 (2008)


A 14-year old juvenile’s statements to an officer admitting to first degree sex offense allegations were admissible as an admission by a party-opponent under G.S. 8C-1, Rule 801(d). The juvenile was adjudicated delinquent for first degree sex offenses with a child, for offenses that occurred when the juvenile was fourteen and the child was seven. A law enforcement officer testified, over the juvenile’s objection, to statements the juvenile made when the officer interviewed him in his mother’s presence, after reading to them and having both of them sign the juvenile rights warning.[The court also found the testimony admissible under G.S. 7B-2407, which governs when admissions by a juvenile may be accepted. That section, however, refers to in court admissions and requires the court to personally address the juvenile with respect to six subjects listed in the statute.]

Admissions by Party-Opponent
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