Brenton Butler was just 15 years old when he was brought in for questioning for the murder of Mrs. Stevens. During Butler’s 12-hour interrogation, he was subjected to emotional, psychological, and physical abuse. Butler’s young age, lengthy interrogation, and the racial biases of his interrogators resulted in his false confession. This coerced confession resulted in Butler being charged with the murder of Mrs. Stevens. It is also what stopped law enforcement from seeking out additional evidence and suspects. If Butler had received an age-appropriate, lawful, ethical interrogation, it is unlikely we would have falsely confessed. Without a confession, the police would’ve searched for additional evidence, which would have exonerated Butler and prevented his arrest.
Research by Goldstein, Condie, Kalbeitzer, Osman, and Geier (2003) evaluated if age, IQ, and history of special education could be used as a predictor for Miranda rights comprehension and the likelihood to give a false confession. 55 boys aged 13 to 18 years old were sampled from a residential post-adjudication facility in Massachusetts (Goldstein et al, 2003). The boys were assessed using the Perceptions of Coercion during Holding and Interrogation Process (P-CHIP) and the Miranda Rights Comprehension Instruments-II (MRCI-II). The boys also filled out a demographics survey, the verbal scales of the Wechsler Individual Achievement Test (WIAT), and the verbal scales of the Wechsler Abbreviated Scale of Intelligence (WASI). Participants were scored on their likelihood to give a false confession after responding to 26 hypothetical police interrogation situations.
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Age was the most significant predictor of a juvenile’s risk of giving a false confession (Goldstein et al, 2003). Participants aged 13-15 were significantly more likely than their 16-18-year-old peers to falsely commit a crime, even when controlling for Miranda comprehension and IQ scores (Goldstein et al, 2003). Miranda rights comprehension showed a positive correlation with age, with younger adolescents (aged 13-15) showing lower comprehension than older adolescents (aged 16-18) (Goldstein et al, 2003). The most common misconception among juveniles was the understanding that they had the right to an attorney both before and during the interrogation process (Goldstein et al, 2003). This is massively important when considering Butler’s case.
As a 15-year-old juvenile, Butler is in an age group of both increased risk for false confession and lower comprehension of his Miranda rights. While Butler was informed of his Miranda rights, he was never given access to a lawyer despite being told one would be arranged for him. The interrogators were likely able to take advantage of Butler’s young age and inexperience with the criminal justice system to push him toward a confession. However, while this study suggests that Butler may have had an inadequate understanding of his Miranda rights, an increased understanding may not have necessarily helped him. Even if Butler fully understood his rights, his confidence in his innocence may have led him to the naïve belief that a lawyer was unnecessary. Similarly, while Butler’s age does put him at increased risk for false confession, that is not the only factor that led to his false confession. The extreme violence and threats Butler described during his interrogation are beyond normal police measures, and it’s possible that the same outcome would have transpired even if Butler was a fully-informed adult at the time of his arrest. It is for this reason, as well as the limited sample size of the study itself, that this study may not be fully applicable to Butler’s case, despite its thorough analysis of data.
Malloy, Shulman, and Cauffman (2014) examined how interrogation techniques affected rates of true and false admissions of guilt among male juvenile offenders. 193 14 to 17-year-old boys incarcerated in a Californian juvenile justice facility were interviewed to assess their experiences with law enforcement and confession (Malloy et al, 2014). The participating boys were informed that their answers to interview questions would be completely confidential, and could not be used in any upcoming pleas or hearings. Interviewers were highly trained in how to conduct the interviews to ensure full comprehension of the questions and wore non-uniform clothing to clearly distinguish themselves from facility staff.
The boys were first asked a series of true/false questions to determine their history with admissions of guilt, both in the form of confessions and plea deals. They were then asked true/false questions about behavior and interrogation techniques they may or may not have experienced during interrogation, including befriending by interrogators, insults, threats, refusal, deception, use of force, and presence of a lawyer, parent, or friend. All participants were given the opportunity to elaborate on experiences, and add any conditions which were not provided by interviewers. Participants were also asked to estimate how long their interrogations lasted. The interviews were conducted individually, in private rooms away from facility staff and other incarcerated juveniles, and lasted approximately one hour.
The analyses of the coded responses found that false admissions of guilt were more commonly made under duress than true admissions of guilt (Malloy et al, 2014). The two most strongly correlated factors with false confession were police refusals and length of interrogation (Malloy et al, 2014). Participants who reported that police refused to give them a break in interrogation were 4.2 times more likely to falsely confess (Malloy et al, 2014). Similarly, interrogation periods lasting over the 2-hour national average were strongly correlated with false confession (Malloy et al, 2014). None of the participants who reported false confessions reported having a lawyer or parent present at the time of confession (Malloy et al, 2014). These factors are greatly relevant to Butler’s experience, where he endured a 12-hour-long interrogation without a lawyer or parent present. This study shows how the extreme length of Butler’s holding and the absence of any friendly adult present could have had a large impact on Butler’s false confession. This study utilized highly skilled interviewers, interviewing tactics, and assurances to prevent lying or exaggeration by self-reporting participants. While this may increase the study’s reliability, it doesn’t change the fact that its sample comes entirely from California, and may not be applicable to youth in Florida. Many of the participants also had a history of prior offenses (an average of 3.1 prior charges), and their behavior may not be applicable to someone like Butler who has no criminal record (Malloy et al, 2014).
Race played a key part in the arrest of Butler, and possibly in his interrogation itself. Sara Appleby (2015) conducted a research study designed to determine if police offers were equally capable of assessing the guilt of White and Black suspects. 80 police officers were recruited through word of mouth from four precincts in suburban and rural southeastern areas (Appleby, 2015). The officers were randomly assigned to watch one of 80 pre-recorded suspect interviews. These suspects had participated in a mock crime, half of which had been instructed to steal a wallet, and half were not. All suspects denied guilt. Each officer received a suspect profile containing background information and inconclusive evidence that could be used against the suspect. After watching the taped interview on a laptop with headphones, the officers rated on a scale how guilty they thought the suspect was, how confident they were in that decision if they felt suspicious when watching the video if they felt the suspect was cooperative and willing to talk, and if they would seek further questioning if this was their case (Appleby, 2015).
The results were analyzed with a 2x2 factor analysis and showed that officers were significantly more likely to judge an innocent Black suspect guilty than an innocent White suspect, with 65% of innocent Black suspects perceived guilty compared to 30% of innocent White suspects (Appleby, 2015). Innocent White suspects were ranked as more cooperative and more willing to talk with investigators than innocent Black suspects (Appleby, 2015). Analyzing these connections between race and guilt presumption is very important when examining Butler’s case. He was only taken in for questioning because his race matched the race of the suspect's description. The officers who interrogated Butler indicated an awareness and negative attitude toward his race, at one point calling Butler a racial slur. Interrogators may have been influenced by Butler’s race, viewing him as guilty and uncooperative despite his innocence. This guilt presumption may have led officers to ignore the possibility of Butler’s innocence, and interrogate Butler with the ferocity and demeanor which eventually led to his false confession. If Butler was not a Black man he would not have been called into questioning, and even if he had, this study indicates it is unlikely a White man in the same position would have been met with the same level of intensity in interrogation, as interrogators would be less likely to view him as guilty and uncooperative.
This study is extensive and evaluates numerous factors connecting suspect traits and behavior to police officers’ assumptions of guilt. Its small sample size, however, may have resulted in type II errors when analyzing the connections between certain factors and race. A larger sample size would prevent any accidental misclassifications of significant effects. Furthermore, this study is not geographically diverse, and likely not representative of racial bias everywhere in the country. While the samples do come from the southeast, it uses suburban and rural precincts. These regions may not be representative of police attitudes in more urban areas like Jacksonville, and as such may not be the best example of how race influenced the behavior of Butler’s interrogators.
The prosecution’s case against Butler relied on Butler’s confession, and on Mr. Stevens’ eyewitness identification of Butler. These pieces of evidence are highly influential to a judge and jury. In Butler’s case, both these pieces of evidence were collected in an unethical manner. Despite not matching the suspect's description, Butler was presented to Mr. Stevens in the back of a police car. Seeing Butler in the back of a police car likely led Mr. Stevens to perceive Butler in a criminal light, leading him in a very emotional and stressful moment to falsely identify Butler as the perpetrator. It has been shown that people are not very good at distinguishing faces outside their racial group, which may have made it easier for Mr. Stevens, a White man, to confuse Butler, a Black teenager, with the actual culprit. As the case proceeded, Mr. Stevens became more confident in his identification of Butler, even when presented with evidence that showed that Butler did not match Mr. Stevens’ initial description of the shooter.
Mr. Steven’s identification of Butler was enough to detain and interrogate him. During interrogation Butler was often interrogated by more than one officer, vaguely and explicitly threatened, denied his right to a lawyer, and refused breaks by his officers. Studies show that teenagers show lower Miranda rights comprehension than adults, and Butler may not have been fully aware of how to exercise his rights. Butler’s race may have influenced the interrogator’s perceptions of his behavior, causing them to view him as guilty and uncooperative, possibly influencing more hostile interrogation behavior. Butler’s hostile, and sometimes physically violent interrogation lasted a grueling 12 hours before he signed a false confession statement.
This case never should’ve gone as far as it did. Butler should not have been presented to Mr. Stevens in as suggestible a position as the back of a police car. When Butler was detained, he should have carefully read his Miranda rights in a way that ensured full comprehension. Statements made by police, such as the statement that a lawyer would be arranged for Butler, should have been followed through on. Most important, Butler should not have been interviewed for longer than the national average of 2 hours. This time cap would have prevented the harsh conditions of police refusals, threats, and intimidation. It would have allowed police to look for more evidence and compile more suspects. If no false confession had been made, evidence could have been more thoroughly evaluated, and perhaps the culprit’s fingerprint in Mrs. Stevens’ purse could have been found earlier, preventing a lengthy, expensive, and psychologically grueling trial for everyone involved. Legislative changes to how we conduct interrogations, including the mandatory presence of adults for minors, time caps on interrogations, and videotaped confessions, can prevent cases like Butler’s from being repeated. Furthermore, increased education on the reliability of eyewitness identification and coerced confessions can help educate our juries, enabling them to protect innocent people like Brenton Butler from serving undue time.
References
- Appleby, S. C. (2015). Guilty stereotypes: The social psychology of race and suspicion in police interviews and interrogations. Retrieved from https://search-proquest-com.ccny- proxy1.libr.ccny.cuny.edu/docview/1658771960?accountid=9967
- Goldstein, N. E. S., Condie, L.O., Kalbeitzer, R., Osman, D., & Geier, J. L. (2003). Juvenile offenders’ Miranda rights comprehension and self-reported likelihood of offering false confessions. Assessment, 10(4), 359-369. https://doi-org.ccny- proxy1.libr.ccny.cuny.edu/10.1177/1073191103259535
- Malloy, L. C., Shulman, E. P., & Cauffman, E. (2014). Interrogations, confessions, and guilty pleas among serious adolescent offenders. Law and Human Behavior, 38(2), 181-193.
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