Hardaway v. Young

At the age of 14, Derrick Hardaway confessed under police questioning to the murder of 11-year-old Robert Sandifer. An Illinois trial court denied Hardaways motion to suppress his confessions as involuntary, and he was convicted of the crime and sentenced to 45 years in prison. After exhausting his state court remedies, Hardaway filed a petition for a writ of habeas corpus. The district court granted the petition, finding that in light of Hardaways age, the lack of a friendly adult presence, and the length of the interrogation, Hardaways confession was involuntary and suppression was required. Because we reluctantly conclude that the Illinois courts application of the totality of the circumstances test to Hardaways confession was not an unreasonable application of clearly established Supreme Court precedent, we reverse the judgment of the district court. We do so, however, with the gravest misgivings and only in light of the stringent standard of review that applies under the applicable law, because we are convinced that the many other indicia under Illinois law of the special care that must be exercised with children as young as 14 strongly suggests that an injustice was committed here.