Female
United States v. Female
Opinion
Lead Opinion
MEMORANDUM *
Juvenile Female V. L.-S. (“Juvenile”) appeals her judgment of juvenile delinquency for possession of cocaine with intent to distribute, in violation of 21 U.S.C. § 841 (a)(1), and conspiracy to possess cocaine with intent to distribute, in violation of 21 U.S.C. § 846 . Juvenile contends that the judgment should be reversed because federal agents violated the Juvenile Delinquency Act (“JDA”) by failing: (1) to advise her of her rights; (2) to notify her parents immediately upon taking her into custody; and (3) to bring her before a magistrate within a reasonable period of time. See 18 U.S.C. § 5033 . Juvenile argues further that her inculpatory statements should have been suppressed because they were involuntary and because she had not been advised of her Miranda rights prior to being questioned. We have jurisdiction pursuant to 28 U.S.C. § 1291 , and affirm.
The JDA requires authorities to advise a juvenile of her rights immediately upon taking her into custody. 18 U.S.C. § 5033 . If a violation of the JDA was so egregious that it deprived the juvenile of due process of law, her conviction must be overturned regardless of any harmless-error analysis. See United…