State v. Benitez, 283 N.C. App. 40 (Apr. 19, 2022)

This Lee county case has a lengthy procedural history, summarized in State v. Benitez, 258 N.C. App. 491, 813 S.E.2d 268 (2018) (Benitez I). Most recently, the case was remanded to the trial court to conduct a review of the totality of the circumstances of the juvenile defendant’s statements to law enforcement to determine if he knowingly and voluntarily waived his Miranda rights. The defendant made the statements at age 13 during two and a half hours of questioning that occurred at the Sheriff’s office. The statements were made through an interpreter and in the presence of the juvenile’s uncle. The juvenile’s initial motion to suppress was denied, and he subsequently pled guilty to first-degree murder.  On remand, the trial court again denied the motion to suppress.

The Court of Appeals rejected the defendant’s argument that the trial court was not in a position to make certain findings without the benefit of expert testimony. Whether a juvenile understood Miranda warnings does not require testimony of an expert. It is, the Court concluded, a question of law to be answered by the court based on the evidence presented by both sides. The trial court appropriately considered evidence regarding the circumstances surrounding the interrogation, as well as the juvenile’s age, experience, education, background, intelligence, and capacity to understand the warnings given him, the nature of his Fifth Amendment rights, and the consequences of waiving those rights.  The trial court did not need further expert testimony on these topics to make its determination. The trial court was also clear that evidence from the capacity hearing, held well after the interrogation occurred, was not used in determining that the defendant understood the Miranda warnings at the time of interrogation. The binding findings of fact, considered as directed by Benitez I, support the trial court’s denial of the motion to suppress. The Court of Appeals therefore affirmed the trial court.

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