J.D.B. v. North Carolina Case Brief

Facts of the case

A North Carolina boy identified as J.D.B. was 13-year-old special education student in 2005 when the police showed up at his school to question him about a string of neighborhood burglaries. The police had learned that the boy was in possession of a digital camera that had been reported stolen.The boy was escorted to a school conference room, where he was interrogated in the presence of school officials. J.D.B.’s parents were not contacted, and he was not given any warnings about his rights under the 1966 decision in Miranda v. Arizona , such as the right to remain silent or to have access to a lawyer. J.D.B. confessed to the crimes, but later sought to have his confession suppressed on the basis that he was never read his Miranda rights. He argued that because he was effectively in police custody when he incriminated himself, he was entitled to Miranda protections. In December 2009, the North Carolina Supreme Court held that it could not consider the boy’s age or special education status in determining whether he was in custody, and because he was not in custody, he was not entitled to Miranda warnings.

CONCLUSION

The Supreme Court determined that remand was warranted because a child’s age properly informed the Miranda custody analysis since, inter alia, (1) a reasonable child subjected to police questioning will sometimes feel pressured to submit when a reasonable adult would feel free to go, and courts can account for that reality without doing any damage to the objective nature of the custody analysis, and (2) a child’s age differed from other personal characteristics that, even when known to police, have no objectively discernible relationship to a reasonable person’s understanding of his freedom of action.

  • Advocates: Barbara S. Blackman for the petitioner Roy A. Cooper III Attorney General of North Carolina, for the respondent Eric J. Feigin Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae, supporting the respondent
  • Petitioner: J.D.B.
  • Respondent: North Carolina
  • DECIDED BY:Roberts Court
  • Location: Smith Middle School
Citation: 564 US _ (2011)
Granted: Nov 1, 2010
Argued: Mar 23, 2011
Decided: Jun 16, 2011
J.D.B. v. North Carolina Case Brief