State v. Saldierna, 371 N.C. 407 (Aug. 17, 2018)

On discretionary review of a unanimous decision of the Court of Appeals, ___ N.C. App. ___, 803 S.E.2d 33 (2017), the court reversed, holding that the trial court’s order denying the defendant’s motion to suppress contained sufficient findings of fact to support its conclusion that the defendant knowingly and voluntarily waived his juvenile rights pursuant to G.S. 7B-2101 before making certain incriminating statements. After the trial court denied the defendant’s suppression motion, the defendant entered a negotiated plea reserving his right to seek review of the denial of suppression motion. After sentencing, the defendant appealed. The Court of Appeals held that the trial court erred by denying the suppression motion because the defendant’s statement, “Can I call my mom,” required the officer to clarify whether the defendant was invoking his right to have a parent present during the interview. The Supreme Court granted the State’s petition seeking discretionary review of that decision, reversed that decision, and remanded to the Court of Appeals for consideration of the defendant’s other challenges to the suppression order. In reversing the Court of Appeals in Saldierna I, the Supreme Court concluded that the statement “Can I call my mom” did not constitute a clear and unambiguous invocation of his right to have his parent or guardian present. On remand in (Saldierna II) the Court of Appeals found that the trial court’s findings of fact did not support its conclusion of law that the State carried its burden of showing that the defendant knowingly, willingly, and understandingly waived his juvenile rights. The Supreme Court granted the State’s petition for discretionary review of the Court of Appeals’ remand decision in Saldierna II. The court noted that the totality of the circumstances analysis requires inquiry into all of the circumstances surrounding the interrogation, including evaluation of the juvenile’s age, experience, education, background, and intelligence, and into whether the juvenile has the capacity to understand the warnings given, the nature of his or her rights, and the consequences of waiving those rights. In applying this test to the custodial interrogation of juveniles, the record must be carefully scrutinized, with particular attention to both the characteristics of the accused and the details of the interrogation. However, a defendant’s juvenile status does not compel a determination that the juvenile did not knowingly and intelligently waive his or her rights. Instead, the juvenile’s age is a factor to consider in the analysis. Turning to the record before it, the court found that the trial court’s findings of fact have adequate evidentiary support and that those findings support the trial court’s conclusion that the defendant knowingly and voluntarily waived his juvenile rights. In reaching a contrary conclusion, the Court of Appeals failed to focus on the sufficiency of the evidence to support the findings of fact that the trial court actually made and to give proper deference to those findings. Thus, the Court of Appeals erred in determining that the record did not support the trial court’s findings to the effect that the defendant understood his juvenile rights. Although the record contains evidence that would have supported a different determination, it was, at most, in conflict. Evidentiary conflicts are a matter for the trial court, which has the opportunity to see and hear the witnesses. The court further found that the trial court’s findings support its conclusion of law that the defendant knowingly, willingly, and understandingly waived his juvenile rights.