Mille Lacs County District Court File No. J40150320
Considered and decided by Anderson, Presiding Judge; Schumacher, Judge;
and Willis, Judge.
The erroneous introduction of statements made in violation of the Miranda right is harmless error under the Juarez standard when the district court's reliance on other evidence in a delinquency adjudication makes the adjudication "surely unattributable" to the error.
The opinion of the court was delivered by: G. Barry Anderson, Judge
Following a bench trial, appellant was adjudicated delinquent for commission of criminal sexual conduct in the second degree. Appellant challenged his adjudication in this court, and we concluded that although the police obtained appellant's statement in violation of his Miranda right and the district court erroneously admitted the statement into evidence at trial, the admission was harmless beyond a reasonable doubt. Because overwhelming evidence of appellant's delinquency existed apart from the statement, we affirmed. The supreme court reversed and remanded this court's determination on the issue of harmless error, and we now consider whether the adjudication of delinquency is consistent with the harmless error standard articulated in State v. Juarez, 572 N.W.2d 286 (Minn. 1997). After careful review of the record, we conclude that, under Juarez, the district court's admission of appellant's statement to police was harmless error. Appellant's delinquency adjudication is, therefore, affirmed.
This appeal, before the court of appeals on remand from the supreme court, has the same underlying facts as In the Matter of the Welfare of T.J.C., Child, 662 N.W.2d 175 (Minn. App. 2003) review granted (Minn. Aug. 5, 2003). We will not, therefore, repeat the facts in full here.
On August 21, 2000, while T.J.C. and M.J. were playing on a trampoline beside M.J.'s house, M.J. reached over and touched T.J.C.'s penis. T.J.C. adjusted himself and said something to M.J.; M.J. then reached over and touched T.J.C.'s penis a second time. M.J.'s mother, watching from a window in the house, witnessed the incident.
As a result of the August 21, 2000 incident, on February 15, 2002, the district court adjudicated T.J.C. delinquent for commission of second-degree criminal sexual conduct in violation of Minn. Stat. § 609.343, subd. 1(a) (2000). The district court based the adjudication on: testimony by M.J.'s mother, testimony by M.J.'s sister, testimony by M.J., a videotaped interview of M.J. discussing the incident, and statements made by T.J.C. to police.
On appeal to this court, we held that T.J.C.'s statements were obtained in violation of his Miranda right, and therefore, the district court should not have considered those statements in its delinquency adjudication. We concluded, however, that the error was harmless, and affirmed T.J.C.'s adjudication. On remand from the supreme court, we now determine that the introduction of T.J.C.'s statement at the adjudication proceedings was harmless error as that doctrine was articulated in Juarez.
Was the district court's erroneous admission of appellant's ...