J.D.B. v. North Carolina

RESPONDENT:North Carolina
LOCATION: Smith Middle School

DOCKET NO.: 09-11121
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: North Carolina Supreme Court

CITATION: 564 US (2011)
GRANTED: Nov 01, 2010
ARGUED: Mar 23, 2011
DECIDED: Jun 16, 2011

Barbara S. Blackman – for the petitioner
Eric J. Feigin – Assistant to the Solicitor General, Department of Justice, for the United States as amicus curiae, supporting the respondent
Roy A. Cooper III – Attorney General of North Carolina, for the respondent

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 inMiranda 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.


Should courts consider the age of a juvenile suspect in deciding whether he or she is in custody forMiranda purposes?

Media for J.D.B. v. North Carolina

Audio Transcription for Oral Argument – March 23, 2011 in J.D.B. v. North Carolina

Audio Transcription for Opinion Announcement – June 16, 2011 in J.D.B. v. North Carolina

Sonia Sotomayor:

This case comes to us from the Supreme Court of North Carolina.

Under our decision in Miranda versus Arizona, a suspect must be warned of his rights before being subjected to custodial police interrogation.

A suspect is in police custody if given all of the objective circumstances a reasonable person in the suspect’s position would not feel at liberty to terminate questioning and leave.

This case presents the question whether the age of a child subjected to police questioning is relevant to the Miranda custody analysis.

Petitioner was a 13-year-old child attending middle school classes when police removed him from his classroom and escorted him to a school conference room.

There, petitioner was met by school administrators and an investigator with the local police force.

For at least 30 minutes, petitioner was questioned about his involvement in two home breakings that occurred the prior weekend.

Eventually, petitioner confessed to the crimes.

Petitioner was charged with breaking and entering and larceny.

He argued in the state court that his confession must be suppressed because he had been interrogated in a custodial setting without first receiving the warnings that Miranda requires.

The (Inaudible) trial and appellate courts rejected this argument.

The North Carolina Supreme Court affirmed refusing to consider petitioner’s age as part of that custody analysis, we reverse.

As we explained in our opinion filed with the clerk of the court today, we conclude that a child’s age properly informs the Miranda custody analysis.

A child’s age is an objective fact that would affect how a reasonable person in the suspect’s position would perceive his freedom to terminate questioning and leave.

Police officers in courts can account for that reality without compromising the objective nature of the custody analysis.

So long as the child’s age was known to the officer at the time of police questioning or would have been objectively apparent to a reasonable officer, a child’s age properly informs the Miranda custody analysis.

The judgment of the North Carolina Supreme Court is reversed.

The case is remanded for the state courts to evaluate whether petitioner was in custody, when police interrogated him, this time taking into account of his age at the time.

Justice Alito has filed a dissenting opinion in which the Chief Justice, Justice Scalia and Justice Thomas joined.