Tyler Edmonds, who was tried as an adult for allegedly helping his sister kill her husband when he was only 13, was rebuffed yesterday by the 5th U.S. Circuit Court of Appeals. He and his mother, Sharon Clay, sued Oktibbeha County officials for coercing a confession out of him while one of the police officer's kept his mother out of the room with his foot against the door. Using that confession, Edmonds was accused of helping his sister Kristi Fulgham pull the trigger to kill her husband, Joey Fulgham, but later acquitted after getting a new trial.
Edmonds told the Jackson Free Press today that the point of the lawsuit was "to right a wrong, to hold certain people accountable."
"While this attempt has not been successful, I am wholeheartedly confident that in the future, thos responsible will be held accountable. I believe in Karma, and I believe that things will work out just the way they are meant to be," Edmonds said.
In 2010, the Jackson Free Press published a long feature about the problems with trying children as adults, including the unreliability of their confessions, using Edmonds as a primary character in the story. The story described how police acquired his confession:
State law follows the spirit of U.S. Supreme Court decisions, which consistently warn that juveniles are vulnerable in police interrogations, and often give false confessions and hurt themselves. "[A] 14-year-old boy, no matter how sophisticated, is unlikely to have any conception of what will confront him when he is made accessible to the police," the high court wrote in Gallegos v. Colorado.
In Haley v. Ohio, the Supreme Court warned: "And when, as here, a mere child—an easy victim of the law—is before us, special care in scrutinizing the record must be used. Age 15 is a tender and difficult age for a boy of any race. He cannot be judged by the more exacting standards of maturity."
However, on the night of May 12 in Starkville, the interrogators of the 13-year-old Edmonds were not employing much "special care"—believing that state law exempted them from having to allow his mother to be present for his interrogation because they might charge him with murder later.
Whitfield kept Clay in the hall outside the room, while Lindsey told Edmonds that his sister had put the murder on him, "that he was the one that killed Joey."
Edmonds said he didn't believe she said that. Then, Lindsay said, "Well, would you believe her if she told you that?"
"Yes, because I don't lie to her, and she don't lie to me," the boy responded.
The officers then put him in the break room with his mother while they went to get Fulgham from another room.
Soon Chief Deputy George Carrithers, who had interrogated Fulgham, walked into the break room and grabbed Edmonds by the arm. "We'll be back in a minute," he said to Clay, not telling her that he was about to have their two suspects talk to each other.
The officer took Edmonds to Lindsey's office. Fulgham walked in, sat down and told Edmonds to hold her hand. "You need to tell them what happened. I've already told them, and they know what happened, and you need to tell the truth," she said to her brother.
Officers then took Edmonds to another room to videotape his statement, but without alerting his mother. At 8:30 p.m., officers read Edmonds his rights off tape and then on tape. At 9:30 p.m., he made his statement, with his mother in the hallway pounding on the door, yelling to be let in. But a deputy had put his foot against the door to keep her out.
The Mississippi Court of Appeals affirmed Edmonds' conviction in 2006, but in 2007, the Mississippi Court reversed it and ordered him a new trial because he was "denied a constitutionally fair trial." In a concurring opinion, then-Justice Oliver Diaz Jr. slammed the lower courts for allowing the beleaguered medical examine Steven Hayne's testimony that he could tell that two people had pulled the trigger—which Diaz called "quackspertise" testimony, while excluding expert testimony on problems with youth confessions.
Diaz then addressed the issue of his confession head-on:
"[H]is mother's removal from the room requires that we reverse and remand for a new trial," Diaz stated. And he argued that admitting the confession violated Edmond's rights against self-incrimination because a 13-year-old child cannot waive their Miranda rights "voluntarily, knowingly and intelligently."
"Tyler could not have understood the nature of the charges against him or the consequences of waiving his Fifth Amendment constitutional rights if he was never told that he was suspected of murder," Diaz said.
Diaz added that the police's use of Fulgham, which he called a "psychological ploy," to coerce Edmonds' statement (and to benefit herself) was "improper influence" and unconstitutional—and it pitted a child against three adults.
"Even if Tyler understood his rights, it is highly unlikely that a naive, 13-year-old child would disobey three adults including two police officers and his beloved sister," Diaz wrote, echoing the research on the unreliable use of adult interrogation techniques on children.
The justice also criticized the court's denial of bail to Edmonds, leaving a 13-year-old who was unlikely to flee and had no history of violence, or even of being disciplined at school, sitting in jail for 14 months awaiting trial. He quoted then-Fifth Circuit Court of Appeals Judge Charles Pickering, who had written that Edmonds had a right to bail in a bond petition hearing before his court.
Pickering wrote that he was "concerned greatly" that Edmonds was arrested May 12, 2003, and did not go on trial until July 19, 2004. "t is inconceivable that the State of Mississippi could not have found some place to incarcerate this young defendant without maintaining him in an adult population for some 14 months before trial."
Pickering slammed the court for ignoring two mental experts it appointed who found that his mental state was declining while he awaited trial, but then ordering that neither expert could testify in his trial.
"Without question, it was the State of Mississippi that was holding this 13-year-old before trial. Petitioner has raised serious constitutional issues about the incarceration of a 13-year-old held some 14 months before trial," Pickering wrote.
Edmonds now lives in Arizona where he is enjoying his freedom, despite the failure of his lawsuit. "At this point, I'm just greatful to be alive, healthy, and free to live as I choose. They say time heals all, and I suppose that is true. As each day passes, I become less and less effected by the negativity that surrounds us all. Life is too short to worry or be miserable. Therefore, I'll not allow the negativity of others to effect my happiness and state of peace. Getting up, dusting off, and saddling back up for another ride," he said.