Children’s Vulnerability During Police Interrogations: The Story of Michael Crowe

The story of Michael Crowe, a 14-year-old child, exemplifies why children need protections during police interrogations. Michael’s traumatic involvement with the criminal justice system began on the night of January 20, 1998 when someone snuck into Stephanie Crowe’s bedroom and stabbed her to death.[1] Police questioned the entire Crowe family the following day, including Michael, Stephanie’s brother.[2] The police read Michael his Miranda rights before questioning him about the murder.[3] However, Michael waived his Miranda rights and spoke with the detectives without an attorney or parent present.[4]

Detectives ignored the fact that on the night of Stephanie’s murder neighbors called the police several times.[5] Neighbors reported that a man was bothering residents and broke into a home in the Crowe’s neighborhood looking for a girl.[6] Detectives had the wrong suspect, but they nonetheless continued to focus their attention on Michael, interrogating him four times.[7]

In the first interview on January 21, 1998, Michael told police that he awoke with a headache around 4:30 a.m. on the morning after Stephanie was murdered, took Tylenol, and went back to his room.[8] Michael retold the same story when police interviewed him for the second time on January 22nd.[9] During the second interrogation, Michael also spoke about how seeing his sister “soaked in blood” the next morning made him cry.[10] He described her as “the best person” and “kind.” Michael expressed anger towards the killer.[11]

            Later that day, police interviewed Michael for a third time for three hours even though he expressed “that he felt sick” at the beginning.[12] Michael once again repeated what he told police during his first and second interviews and said:

I feel like I just … I spent all day away from my family. I couldn’t see them… I feel like I’m being treated like I killed my sister, and I didn’t. It feels horrible, like I’m being blamed for it … Everything I have is gone. Everything. You won’t even let me see my parents. It’s horrible.[13]

Detectives ignored Michael’s pleas and continued to interrogate him by giving a computer stress voice analyzer test.[14] Detectives told Michael that the test proved he was deceiving them and questioned whether there was something he was “blocking out” in his “subconscious mind.”[15] Michael continued to deny that he murdered his sister even as detectives pressured him about whether he needed to confess something.[16] Detectives began to tell Michael that police “found blood in his room, lifted fingerprints off the blood stains, and that the police” knew he killed Stephanie.[17] As Michael repeatedly denied killing his sister, detectives told him that maybe he simply did not remember killing his sister.[18] An emotional and confused Michael asked the detective “if he was sure” that he had killed his sister. To which the detective responded, “‘I’m sure about the evidence. Absolutely.’”[19]

            Finally, detectives interviewed Michael for a fourth time for over six hours on January 23, 1998.[20] Detectives used various interrogation tactics to make Michael confess.[21] Detectives again told Michael that the police had evidence which proved he murdered Stephanie.[22] The detectives also played a “game” with Michael that forced Michael to explain crime scene evidence, but with a rule that Michael could not say “‘I don’t know.’”[23] Detectives continued to tell Michael that he killed Stephanie and he did not remember and “introduced the idea that there were ‘two Michaels,’ a ‘good Michael’ and a ‘bad Michael.’”[24] Finally, detectives told Michael “if he confessed he would get help rather than go to jail.”[25] The detectives continued to pressure Michael into confessing, which resulted in the following exchange:

  1. If I tell you a story, the evidence is going to be a complete lie.

Q. Well, then, tell us the story.

A. Well, I’ll lie. I’ll have to make it up.

Q. Tell us the story, Michael.

A. You want me to tell you a little story?

Q. Tell us the story. What happened that night?

A. Okay. I’m going to warn you right now. It is a complete lie.

Q. Tell us the story.

A. Okay. This is true. I am extremely jealous of my sister.

Q. Okay.

A. She’s always had a lot of friends and good friends and stuff like that. She was friends with people my age, all the popular girls and stuff like that. That’s true. Okay…Okay. Here is the part where I’ll start lying. That night I thought about her. I couldn’t take it anymore. Okay. So I got a knife, went into her room and I stabbed her….

Q. How many times did you stab her?

A. It’s going to be a lie. Three times…

Q. Tell me what the truth is.

A. The only reason I’m trying to lie here is because you presented me with two paths. I’d rather die than go to jail.[26]

The detectives finally had what they saw as a confession and proceeded with criminal charges against Michael.[27] Michael’s story stands as a testament to why the legal community and society as a whole must fight to ensure that the legal injustice, psychological manipulation, and emotional trauma Michael endured during police interrogations does not happen to any other child.


[1] Crowe v. Cty. of San Diego, 608 F.3d 406, 417 (9th Cir. 2010).

[2] Id. at 418.

[3] Id.

[4] Id.

[5] Id. at 417.

[6] Id.

[7] Id. at 418-419.

[8] Id. at 418.

[9] Id. at 418-419.

[10] Id. at 419.

[11] Id.

[12] Id.

[13] Id.

[14] Id.

[15] Id.

[16] Id.

[17] Id.

[18] Id. at 420.

[19] Id.

[20] Id.

[21] Id.

[22] Id.

[23] Id. at 420-421.

[24] Id. at 421.

[25] Id. at 422.

[26] Id.

[27] Id.

Anti-Prostitution Laws are Hurting Juveniles

The movement to decriminalize sex work has been pushed by sex workers for decades and has gained national popularity in criminal justice discussions. Decriminalizing sex work would halt arrests and charges for prostitution. While this may not seem like a juvenile justice issue, there is a small but significant group who have been impacted by anti sex work laws: juveniles arrested for prostitution.

The Trafficking Victims Protection Act defines sex trafficking as recruiting, patronizing, or otherwise causing a person under 18 years old to participate in a commercial sex act.[1] Most states have statutory rape laws which state a person under a certain age cannot consent to sex with an adult. In Texas, for example, an adult cannot engage in sexual contact with a person under 17 years old.[2] These laws indicate a general consensus that minors cannot consent to sex work or sex with adults. If that is the case, the 290 children aged 0-17 who were arrested in 2019 for prostitution should have been treated as victims instead of criminals.[3]

The interception of child trafficking victims and criminal prostitution laws can be seen in the 2010 Texas case In re B.W. This case involved a 13 year old girl who was arrested for prostitution in Texas.[4] The offense was filed in adult criminal court, where it was discovered the arrestee was a child. [5] The prostitution charge was then dismissed, but B.W.’s involvement with the justice system was not over. The charges were transferred to juvenile court, where B.W. pleaded true to the allegation, which is the equivalent of pleading guilty in adult court, and was sentenced to 18 months probation.[6]

On appeal, the Supreme Court of Texas ruled that because the legislature has determined children under 14 do not have the mental capacity to consent to sex with anyone, they are exempt from prostitution charges. [7] This was a win for B.W. and child sex trafficking victims all over Texas, but the impact of criminalization was already felt. B.W. had already been subjected to arrest and booking in adult court. In re B.W. protects juveniles who are 14 or younger, but leaves other teenagers in Texas age 15-16 vulnerable to prostitution charges and arrests. There is not clear data on how many 15 and 16 year olds have been arrested for prostitution in Texas since In re B.W., but Texas makes up part of the 290 total arrests, indicating there have been some. Not all arrests lead to charges, but all arrests traumatize the children who are subject to them.

The effects of arrest on juveniles cannot be taken lightly. Youth who have been arrested are much less likely than their peers to graduate high school or enroll in college.[8] A child who is arrested and is then confined at a juvenile detention facility is virtually guaranteed to not finish their high school education.[9] Young people without a high school degree will face more difficulties finding stability and employment.[10] High school dropouts may face an increased risk of grooming by sex traffickers because they are not around teachers who recognize the signs and can refer the student to school counseling or other services.

Criminalization of sex work is causing lifelong effects in vulnerable juveniles. While full decriminalization of sex work may not be popular in every state, laws preventing minors from being charged with prostitution would go a long way in protecting the country’s youth.


[1] 18 U.S.C. § 1591
[2] Tex. Penal Code §21.11
[3] Office of Juvenile Justice and Delinquency Prevention, https://www.ojjdp.gov/ojstatbb/crime/ucr.asp?table_in=1
[4] In re B.W., 313 S.W.3d 818
[5]Id.
[6] ​​Id.
[7] Id.
[8] David S. Kirk & Robert J. Sampson, Juvenile Arrest and Collateral Education Damage in the Transition to Adulthood, 36, 47 (American Psychological Association 2013).
[9] Id at 55
[10] Id.

New Research Analyzes the Effects of Foster Care on Children’s Well-Being

New research, published in April analyzes the effectiveness of the foster care system in Michigan.[1] In what is perhaps a surprising result, children who enter the foster care system are better off than their peers who remain with their parents.

A recent study showed that 6% of all American children spend some amount of time in the foster care system. That number is much higher for children of color: 10% of Black children enter the foster care system at some point in their childhood, and 15% of Native American children enter the system at some point.[2]

Economists have been studying foster care outcomes since 2007. Previous research studied foster care outcomes from Illinois and found that foster care hurt children more than leaving children in the home.[3] That study looked at children on the margin – those who were on the boundary between being removed from the home and staying with parents – to show that those who were removed from the home were convicted of crimes at higher rates, and had lower long-term incomes.

This study uses the same research design in Michigan, and suggests the opposite result: these authors found that foster care reduced the likelihood that children were alleged to be victims of abuse by 52%, increased daily school attendance by 6%, and a small decrease in findings of juvenile delinquency.

So why is Michigan so different from Illinois? These authors suggest that Illinois’ foster care system was especially harmful, so rather than foster care in general harming children, Illinois’ implementation of foster care was to blame. As evidence, they show that Illinois children spent the longest amount of time in the system in the country, while Michigan is closer to average.

Another possible explanation is that foster care has simply improved over time. The authors cite to a child trends study which shows that children are now spending less time in the system, and are being placed with family members more often.[4]

What does this mean for those interested in child policy? It’s not quite clear. Hopefully, research like this will prompt other states to look at their own foster care programs to see if they are more like Illinois or Michigan. We know that removing a child from the home is a drastic measure that should only be taken when absolutely necessary. Nothing here suggests that more children should enter foster care, only that in this particular jurisdiction, it is effective for the child on the bubble between removal and remaining in the home.

My takeaway is this: good foster care that helps children is possible. It might look like shorter stays in the system and more placements with family members. It definitely looks like states should be analyzing their foster care systems with the most advanced tools possible, like the ones these economists employed.


[1] Max Gross & E. Jason Baron, Temporary Stays and Persistent Gains: The Causal Effects of Foster Care, American Economic Journal: Applied Economics 14(2): 170–199 (2022).

[2] Emanuel Wildeman, Cumulative Risks of Foster Care Placement by Age 18 for U.S. Children, 2000–2011, PLoS ONE 9(3): e92785 (2014).

[3] Joseph J. Doyle, Jr., Child Protection and Child Outcomes: Measuring the Effects of Foster Care, American Economic Review 97 (5): 1583-1610 (2007) (“the results suggest that children on the margin of placement tend to have better outcomes when they remain at home, especially older children.”).

[4] Child Trends, Child Trends Databank, https://www.childtrends.org/indicators/foster-care.