In the Matter of L.I., 205 N.C. App. 155 (2010)

Reversed and Remanded

Although the juvenile’s statement that she possessed marijuana was the result of improper interrogation and should have been suppressed, the juvenile did not argue that she was subjected to coercion, and therefore, the trial court properly admitted as evidence the marijuana the juvenile possessed. The exclusion of physical evidence obtained as a result of a Miranda violation requires evidence of “actual coercion” by law enforcement. The evidence revealed there was no actual coercion where the juvenile was not deceived, held incommunicado, threatened or intimidated, promised anything, or interrogated for an unreasonable period of time; nor was there evidence that the juvenile was under the influence of drugs or alcohol or that her mental condition was such that she was vulnerable to manipulation.

Motions to Suppress
Custodial Interrogation
Physical Evidence
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