Summary
The Supreme Court held that a child's age is a relevant factor in determining whether a juvenile suspect is in custody for purposes of Miranda v. Arizona.
Topics
Practice areas
Questions Presented
- Whether a juvenile suspect's age is a relevant factor in the Miranda custody analysis.
Holdings
- A child's age properly informs the Miranda custody analysis when the officer knew or could objectively ascertain the child's age.
Key quotations
“We hold that a child’s age properly informs the Miranda custody analysis.” (279)
Factual background
J.D.B., a 13‑year‑old middle‑school student, was taken from class by a school resource officer, escorted to a closed conference room, and questioned by police for about 30‑45 minutes without Miranda warnings. He eventually confessed after being told he might be placed in juvenile detention.
Procedural history
The trial court denied J.D.B.'s motion to suppress statements obtained during a schoolhouse interrogation. The North Carolina Court of Appeals affirmed, and the North Carolina Supreme Court held that age was not a factor in the custody analysis. The United States Supreme Court granted certiorari to resolve whether a juvenile's age is relevant to Miranda custody analysis.
Remand instructions
Remand to the North Carolina courts to determine whether J.D.B. was in custody under the proper analysis, taking into account his age.