State v. Miller, 2026 Del. Super. LEXIS 310 (Del. Super. Ct. 2026)
The Delaware Superior Court granted a motion to suppress statements from a police interrogation of a 15-year-old youth with ADHD, finding that the youth did not knowingly, voluntarily, or intelligently waive his Miranda rights.
The court reasoned:
In summary, over the course of approximately three hours, a fifteen-year-old child was woken up, handcuffed, placed in a holding cell, and then interrogated by two detectives who misled him about the reason for their questioning. Despite informing detectives of a recent Dover Behavioral Health stay, and displaying what appears to the Court to be clear signs of mental disorder and distress, detectives did not alter their questioning standards. Mr. Miller did not receive the opportunity to consult witha trusted adult, despite requesting his mother at least four times – and may have been denied that opportunity, at least, in part, because detectives misled his mother about why they wanted to question Mr. Miller.
Both doctors who testified in this matter agree Mr. Miller has severe ADHD. From the Court’s observation – of both the interview and of Mr. Miller during the hearings relevant to this motion – Mr. Miller exhibits clear signs of that severe ADHD. Both doctors also agreed Mr. Miller’s severe ADHD could impact his ability to comprehend. Dr. Gould testified Mr. Miller’s anxiety disorder could exacerbate his ADHD symptoms during a stressful situation. “The pressure of custodial interrogation is so immense that it can induce a frighteningly high percentage of people to confess to crimes they never committed. That risk is all the more troubling- and recent studies suggest, all the more acute, when the subject of custodial interrogation is a juvenile.”
. . . .
Delaware law requires special scrutiny of any child’s waiver of his Miranda rights. The State bears the burden of showing any such waiver was made knowingly, voluntarily, and intelligently. The State has not met its burden. Accordingly, Mr. Miller’s Motion to Suppress is GRANTED.
