Supreme Court Decides J.D.B. v. North Carolina

On June 16, 2011, the Supreme Court decided J.D.B. v. North Carolina, No. 09-11121, holding that in determining whether a child was in custody and thus entitled to receive Miranda warnings, courts must consider the child's age if it was known to an officer at the time of police questioning, or would have been objectively apparent to a reasonable officer.

In Miranda v. Arizona, the Supreme Court held that, because of the inherently coercive nature of a custodial interrogation, certain steps must be taken to protect an individual's constitutional right against self-incrimination, including giving the now-familiar Miranda warnings.  These steps are only required where an interrogation is custodial, and the analysis of whether an individual is in custody is an objective inquiry.  The question presented in J.D.B. is whether a child's age informs the in-custody analysis.

After J.D.B. was seen in the vicinity of several home invasions, and a missing item was seen in his possession at school, school officials and a police officer questioned J.D.B., 13 years old at that time, for more than 30 minutes in a school conference room with the door closed.  J.D.B. first denied any involvement, but after pressure to do the right thing, he confessed to participating in the break-ins.  Only after he confessed was J.D.B. advised that he did not have to answer questions and that he was allowed to leave.

Juvenile petitions were filed against J.D.B., and his public defender challenged them on the ground that J.D.B. was not properly given Miranda warnings.  After the trial court denied the suppression motion and concluded that J.D.B. was not in custody at the time of the interrogation, J.D.B. admitted all counts.  The North Carolina Court of Appeals and Supreme Court affirmed the trial court's decision and declined to extend the objective in-custody inquiry to include a child's age.

The Supreme Court reversed, holding that age is a relevant part of the analysis, and remanded for a reconsideration of whether J.D.B. was in custody at the time of interrogation.  The Supreme Court explained that a child's age may, in some circumstances, affect how a reasonable person would perceive his or her freedom to leave. 

The Court rejected the argument that including a child's age muddies the objective analysis.  The Court explained that if the child's age is known to an officer, or is objectively apparent, including age in the analysis does not require an officer to "consider circumstances ‘unknowable'" or to "‘anticipat[e] the frailties or idiosyncrasies' of the particular suspect" being questioned.

A child's age, the Court noted, is different from other personal characteristics that "have no objectively discernible relationship to a reasonable person's understanding of his freedom of action."  Childhood leads to certain objective conclusions, including that children are more susceptible to influence and outside pressures.  Moreover, wrote the Court, "[n]ot once have we excluded from the custody analysis a circumstance that we determined was relevant and objective, simply to make the fault line between custodial and noncustodial ‘brighter.'" Thus, consideration of a child's age is appropriate to determine whether that child's interrogation was custodial.

Justice Sotomayor delivered the opinion of the Court in which Justices Kennedy, Ginsburg, Breyer, and Kagan joined.  Justice Alito filed a dissenting opinion in which Chief Justice Roberts and Justices Scalia and Thomas joined. 

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