J. D. B. v. North Carolina

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J. D. B. v. North Carolina, 564 U.S. 261 (2011), was a case in which the Supreme Court of the United States held that age and mental status are relevant when determining police custody for Miranda purposes, overturning its prior ruling from seven years before. J. D. B. was a 13-year-old student enrolled in special education classes whom police had suspected of committing two robberies. A police investigator visited J. D. B. at school, where he was interrogated by the investigator, a uniformed police officer, and school officials. J. D. B. subsequently confessed to his crimes and was convicted. J. D. B. was not given a Miranda warning during the interrogation, nor an opportunity to contact his legal guardian .

During the trial, attempts to suppress the statements given by J. D. B. because he was not given a Miranda warning were denied on the grounds that J. D. B. was not in police custody. J. D. B. appealed.

The North Carolina Supreme Court held that the Supreme Court's ruling in _Yarborough v. Alvarado _ barred them from determining whether or not he was in custody based on his age. The court determined that a reasonable adult would've felt free to leave; consequently, J. D. B. was not in custody. Thus the court affirmed the ruling of the trial court. J. D. B. appealed, and the U.S. Supreme Court granted certiorari.

The U.S. Supreme Court argued that the age and mental status of an individual can take part in the psychological effect that he faces during police interaction. The reasoning was similar to that of the 1970 Kentucky Supreme Court case of Allee v. Commonwealth, which held that the age and mental status of an individual is relevant in determining whether his statements are involuntary. Based on these reasons, the U.S. Supreme Court reversed the North Carolina Supreme Court and remanded for further proceedings. The North Carolina Supreme Court on remand then determined that J. D. B. was in custody, and remanded for further proceedings.

Contents

• 1 Background

  • 1.1 Miranda warnings

  • 1.2 Police investigation

  • 1.3 Trial and appeal

• 2 Opinion of the court

  • 2.1 Relevancy of age

  • 2.2 Miranda as an objective test

  • 2.3 Dissent

• 3 Reception and subsequent developments

• 4 Notes

• 5 References

Background

(https://en.wikipedia.org/w/index.php?title=J._D._B._v._North_Carolina&action=edit&section=1 "Edit section: Background")

Miranda warnings

(https://en.wikipedia.org/w/index.php?title=J._D._B._v._North_Carolina&action=edit&section=2 "Edit section: Miranda warnings")

A Miranda warning is an explanation of a suspect's rights that must be given by law enforcement before interrogation. It stems from the 1966 _Miranda v. Arizona _ case, and is based primarily on the Fifth Amendment right against self-incrimination. If a defendant in custody is not notified of their rights via a Miranda warning, any confession they give may not be admissible in court . If a defendant is not in police custody, however, police are free to question suspects without informing them of their rights, and their statements may still be admissible.

Police investigation

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J. D. B. was a 13-year-old student attending Smith Middle School in Chapel Hill , North Carolina when he was taken out of class by a uniformed police officer and questioned. J. D. B. had been questioned previously by the police when they saw him in the neighborhood where two home break-ins had occurred. After questioning J. D. B. the first time, police learned that a digital camera matching the description of a stolen item had been seen in the possession of J. D. B. This prompted the juvenile investigator assigned to the case to go to the school to question J. D. B. Upon arriving at the school, the investigator informed the uniformed police officer on detail at the school and members of the school's administration. The uniformed officer interrupted the class J. D. B. was in and escorted him to a school conference room, where J. D. B. was subsequently questioned by the investigator, police officer, and members of the school's administration for 30 to 45 minutes. Prior to the questioning, J. D. B. was neither given Miranda warnings nor an opportunity to speak to his legal guardian, nor was he informed that he was free to leave the room.

Initially J. D. B. denied any wrongdoing. After being confronted with the stolen camera and after the urging of a school administrator, J. D. B. confessed to the break-ins. It was at this point, after the confession, that the investigator informed J. D. B. that he could refuse to answer questions and that he was free to leave. J. D. B. indicated that he understood and then proceeded to provide further details about the crime, including the location of the stolen property. J. D. B. wrote a statement at the investigator's request. He was allowed to leave to catch the bus home.

Trial and appeal

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Two juvenile petitions were filed against J. D. B. Each alleged one count of larceny and one count of breaking and entering . J. D. B.'s public defender moved to suppress J. D. B.'s statements and the evidence derived from them, arguing that J. D. B. had been interrogated in police custody without the required Miranda warnings. The trial court decided that J. D. B. was not in custody, and denied the motion. The North Carolina Supreme Court affirmed with a divided panel, "declin[ing] to extend the test for custody to include consideration of the age... of an individual subjected to questioning by police".

The Supreme Court granted certiorari to determine whether the Miranda custody analysis includes consideration of a juvenile suspect’s age. The American Civil Liberties Union , American Bar Association , and the National Association of Criminal Defense Lawyers were among the organizations that filed amicus briefs in support of J. D. B. The attorneys general of 30 states and 2 unincorporated territories filed an amicus brief in support of North Carolina.

Opinion of the court

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Justice Sotomayor authored the Court's opinion.

Associate Justice Sonia Sotomayor wrote the opinion for the Court. The Court held that a child's age properly informs the Miranda custody analysis.

Relevancy of age

(https://en.wikipedia.org/w/index.php?title=J._D._B._v._North_Carolina&action=edit&section=6 "Edit section: Relevancy of age")

The Court underscored the dangers of not applying age to the custody analysis, writing:

to hold... that a child's age is never relevant to whether a suspect has been taken into custody— and thus to ignore the very real differences between children and adults— would be to deny children the full scope of the procedural safeguards that Miranda guarantees to adults.

The opinion cited _Stansbury v. California _, where the Court held that a child's age "would have affected how a reasonable person" in the suspect's position "would perceive his or her freedom to leave". _Yarborough v. Alvarado _ was also cited, where the Court wrote that a child's age "generates commonsense conclusions about behavior and perception". Finally, the Court pointed out that the law reflects the idea that a child's judgment is not the same as an adult's, in the form of legal disqualifications on children as a class (e.g. limitations on a child's ability to marry without parental consent).

Miranda as an objective test

(https://en.wikipedia.org/w/index.php?title=J._D._B._v._North_Carolina&

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