J. D. B. v. North Carolina
564 U.S. 261, 2011 U.S. LEXIS 4557, 180 L. Ed. 2d 310 (2011)
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Rule of Law:
A child's age, when known to an interrogating officer or objectively apparent to a reasonable officer, is a relevant factor that must be included in the totality-of-the-circumstances analysis to determine whether the child is in custody for Miranda purposes.
Facts:
- Two home break-ins occurred in a neighborhood, and various items were stolen.
- J.D.B., a 13-year-old seventh-grade student, was seen in the neighborhood where the crimes occurred.
- Police learned that a digital camera matching the description of a stolen item had been seen in J.D.B.'s possession at his middle school.
- Police Investigator DiCostanzo went to the school to question J.D.B.
- A uniformed school resource officer removed J.D.B. from his social studies class and escorted him to a school conference room.
- Inside the closed-door conference room, J.D.B. was questioned for 30 to 45 minutes by DiCostanzo, the school resource officer, an assistant principal, and an administrative intern.
- During the questioning, J.D.B.'s grandmother and legal guardian was not contacted, and J.D.B. was not informed he was free to leave.
- After the assistant principal urged him to 'do the right thing' and Investigator DiCostanzo mentioned the possibility of a 'secure custody order' leading to juvenile detention, J.D.B. confessed to the break-ins.
Procedural Posture:
- Two juvenile petitions were filed against J.D.B. in North Carolina state court, alleging breaking and entering and larceny.
- J.D.B.'s public defender filed a motion in the trial court to suppress his confession, arguing it was obtained during a custodial interrogation without Miranda warnings.
- The trial court denied the motion to suppress, ruling that J.D.B. was not in custody during the interrogation.
- J.D.B. was adjudicated delinquent by the trial court.
- J.D.B. appealed to the North Carolina Court of Appeals, an intermediate appellate court, which affirmed the trial court's decision in a divided opinion.
- J.D.B. then appealed to the North Carolina Supreme Court, the state's highest court, which also affirmed, holding that a suspect’s age is not a relevant factor in the Miranda custody analysis.
- The United States Supreme Court granted certiorari to review the North Carolina Supreme Court's decision.
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Issue:
Does the Miranda custody analysis, which determines whether a person would feel free to terminate a police interrogation and leave, require consideration of a juvenile suspect's age?
Opinions:
Majority - Justice Sotomayor
Yes, the Miranda custody analysis must include consideration of a juvenile suspect's age. The inquiry into whether a suspect is in custody is an objective one that examines the totality of the circumstances to determine if a reasonable person would feel free to leave. It is a commonsense reality, recognized in other areas of law, that children are more vulnerable to pressure and less mature than adults. A reasonable child subjected to police questioning will sometimes feel compelled to submit when a reasonable adult would feel free to go. Therefore, so long as the child's age was known to the officer or would have been objectively apparent, it is a relevant circumstance that must be considered to avoid an absurd analysis that evaluates a child's situation through the eyes of an adult.
Dissenting - Justice Alito
No, the Miranda custody analysis should not be modified to include a suspect's age. A core virtue of Miranda's prophylactic rule is the ease and clarity of its application, which is achieved through a one-size-fits-all, objective reasonable-person test focused on the external circumstances of the interrogation, not the personal characteristics of the suspect. Introducing age transforms this clear rule into a highly fact-intensive standard, opening the door to consideration of other personal traits like intelligence or education and undermining Miranda's predictability. The existing voluntariness test already provides a sufficient, flexible framework to account for a juvenile's specific vulnerabilities and ensure a confession was not coerced, making this fundamental change to the Miranda custody test unnecessary.
Analysis:
This decision significantly modifies the Miranda custody analysis by incorporating a personal characteristic of the suspect—age—into what was previously understood as a purely objective test based on external circumstances. It requires law enforcement and courts to reframe the 'reasonable person' standard as a 'reasonable person of the same age' when the suspect is a juvenile. This holding strengthens protections for minors during police interrogations, making it more likely that they will be deemed 'in custody' and thus entitled to Miranda warnings. However, it also complicates the previously clear-cut custody test and may lead to future litigation over whether other objective personal characteristics should also be considered.
