In a suit charging several St. Clair County Sheriff’s Department officials with forcing a mentally impaired teenager to falsely confess, two Northwestern University law centers, representing now 18-year-old Trevon Yates, are set to begin the discovery process as they await a court date.
The suit, filed in late August against St. Clair County and seven deputies, came one year after Yates’ arrest. The officers charged Yates, who was 17 at the time, with armed robbery for using a gun to steal a cell phone during a Craigslist deal.
Sheriff’s deputies arrested Yates after investigators used text messages on one victim’s phone to trace its previous locations, leading them to question two Belleville teenagers. One of the teens described a suspect, “Trayvon,” as a 17-year-old black male living in Belleville, with a sleeve of tattoos on his arm, gold teeth, earrings and a box cut with stripes along the side of his head.
Although he lived in East St. Louis, several officers went to the Yates home that evening where they arrested Trevon. He did not match the suspect description and had met neither of the teens the department had already questioned.
According to the suit, Yates has the cognitive ability of a nine or 10-year-old and an IQ of 60, which made him more susceptible to questionable interrogation tactics.
St. Clair County Sheriff Rick Watson, however, said their department didn’t know about Yates’ mental condition during the interrogation.
“No one told us anything,” Watson said. It wasn’t until “the doctor made the diagnosis…nine months later.”
Following the diagnosis, which one of Yates’ lawyers described as an “intellectual disability,” the St. Clair County State’s Attorney’s office dropped all charges against Yates and released him from jail.
Yates’ mental illness meant he was not able to “knowingly waive his constitutional rights,” said Brendan Kelly, St. Clair County State’s Attorney in an email. This made Yates’ confession inadmissible. “That decision was not based on any alleged misconduct by investigating officers.”
The suit accused several St. Clair County Sheriff’s Department officers and investigators of coercive interrogation and false arrest, civil conspiracy, malicious prosecution and intentional infliction of emotional distress, according to a statement issued by the Roderick and Solange MacArthur Justice Center, one of the law firms involved in the suit on behalf of Yates. Both the MacArthur Justice Center and the Center on Wrongful Convictions of Youth, based at Northwestern University, specialize in cases on police misconduct and false confessions.
According to the suit, Trevon was not told why he was being arrested when officers arrived at his East St. Louis home.
Trevon was “brought into the station in handcuffs,” but had “no idea why he’s there,” said Laura Nirider, co-director at the Center on Wrongful Convictions of Youth and an NU law professor.
Nirider, who saw the recorded interrogation, said it lasted between two and two-and-a-half hours, during which Yates “denies it and denies it and denies it.” Yates’ questioners told him he had been identified and would be dealt with more leniently if he confessed.
“He then agrees to confess at which point they spoon-feed him,” the facts about the robbery, Nirider said. “He has to ask them how many victims were in the car. These should be red flags.”
Watson denied that officers “spoon-fed” Yates the facts.
“I can tell you that is not fact,” he said. “Anybody can make an allegation, they can get on TV and they can say anything they want to, but they have to prove it in a court of law.”
Juveniles are between two and three times more likely than adults to confess during an investigation, Nirider said. According to a 2012 report on investigating and interrogating juveniles by the International Association of Chiefs of Police, law enforcement today “is not adequately trained.”
According to the IACP report, because the prefrontal cortex, which is responsible for judgment, decision-making and regulating responses to fear or stress, is not fully developed until the end of adolescence, it is more difficult for juveniles to weigh their options, so they tend to place greater emphasis on instant gratification—such as an end to police questioning.
In 2011 the U.S. Supreme Court recognized this disparity as a cause for concern, writing in a decision that children “possess only an incomplete ability to understand the world around them.” The following year, the immaturity of the adolescent brain factored large in Miller v Alabama, in which the court found that mandatory life without parole for juveniles – even in the case of homicide – amounted to cruel and unusual punishment.
During Yates’ interrogation he offered to take a lie detector test, which was never given, and let investigators examine his cell phone, which could not be tied to the robbery, according to the suit.
Despite the suit and all the charges against Yates being dropped, Watson said Yates remains a suspect, and noted that although Yates’ lawyers say he falsely confessed, they had not denied that he committed the crime.
“No one has said that he did not participate in this robbery,” Watson said, although the lawsuit states “Trevon Yates was and is innocent of the armed robbery of Nicole McCoy and Harpreet Singh.”
Nirider said the only evidence against Yates was his false confession, and which “boils down to the same thing” as saying he is innocent.
Since 1986, 137 cases in Illinois have been exonerated, according to the National Registry of Exonerations, a joint project of the University of Michigan and Northwestern University law schools. In 65 percent of these exonerated cases, official misconduct was a contributing factor. False confession was a factor in 39 percent of these cases.
Watson said the case comes down to whether or not Yates can understand Miranda Rights.
“Even during the questioning he told the investigators he was taking classes to obtain his GED,” Watson said, adding that if Yates was able to pass a GED test, he was able to pass on his rights.
Watson said he does not fear going to court and he stands behind the officers involved in the suit.
He explained that in cases such as this, law enforcement officers have qualified immunity, which protects them from criminal liability as long as “they do everything they’re trained to do and they do it correctly…or in good faith.”
“We welcome going to court,” he said. “Oh yeah. We’re not afraid to go to court.”