People v. I.F. (In re I.F.)

*740 Appellant I.F., then age 12, and his sister L.F., age 8, were home alone on the morning of April 27, 2013. During the course of the morning, someone entered L.F.'s bedroom and stabbed her to death. Later that day, and in the days that followed, I.F. made a series of inconsistent and cumulatively incriminating statements to police.

On May 14, 2013, a petition was filed under Welfare and Institutions Code section 602 alleging that I.F. committed murder ( Pen. Code, § 187, subd. (a) ), 1 and personally used a knife in the commission of the offense (§ 12022, subd. (b)(1)). Following a contested jurisdictional hearing, the juvenile court sustained the petition and found true the allegation that I.F. personally used a knife in the commission of the crime.

*465 I.F. appeals, arguing the juvenile court erroneously admitted his pre-arrest statements in violation of Miranda v. Arizona (1966) 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 ( Miranda ). We agree that two of four challenged statements were inadmissible. Because the Miranda error was not harmless beyond a reasonable doubt under *741 Chapman v. California (1967) 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 ( Chapman ), we…