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J.D.B. v. North Carolina

Supreme Court of the United States · 2011 · Criminal Procedure

Criminal ProcedureMirandaCustodyJuvenile InterrogationMirandacustodyjuvenileage

Facts

J.D.B., a 13-year-old seventh grader, was taken from his classroom by a uniformed school resource officer and escorted to a closed conference room at school. There, with two police officers and two school administrators present, he was questioned for 30 to 45 minutes about neighborhood break-ins without Miranda warnings, without being told he could leave, and without being given a chance to speak with his grandmother, his legal guardian. During questioning, the assistant principal urged him to do the right thing, and the investigator warned him about the possibility of a secure custody order and juvenile detention. After that warning, J.D.B. confessed; only then was he told he could refuse to answer questions and was free to leave.

Issue

Whether a child's age is relevant to the Miranda custody inquiry. More specifically, when police question a juvenile, must courts consider the suspect's age as part of the objective analysis of whether a reasonable person would have felt free to terminate the interrogation and leave?

Rule

Miranda custody remains an objective inquiry asking first what circumstances surrounded the interrogation and second whether, given those circumstances, a reasonable person would have felt at liberty to terminate the interrogation and leave, i.e., whether there was a formal arrest or restraint on freedom of movement of the degree associated with formal arrest. In applying that objective test, a child's age must be considered when the age was known to the officer at the time of questioning or would have been objectively apparent to a reasonable officer, because age can affect how a reasonable person in the suspect's position would perceive freedom to leave.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Portland, Oregon, detectives questioned Maya Torres about a neighborhood fire in a small interview room at her middle school for 25 minutes. Maya looked about 12, wore a school ID showing seventh grade, and was never told she could leave; the detectives gave no Miranda warnings.

In deciding whether Maya was in custody for Miranda purposes, which approach is most consistent with the governing rule?

Explanation. Miranda custody is determined objectively by examining the circumstances of the interrogation and asking whether a reasonable person in the suspect’s position would have felt free to terminate the questioning and leave. When the suspect is a child, age is a relevant objective circumstance if it was known to the officers or objectively apparent. The majority rejected a categorical rule excluding age and held that a reasonable child may feel unable to leave when a reasonable adult would feel free to do so.