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Name: J.D.B. v. North Carolina
Case #: 09-11121
Court: US Supreme Court
District USSup
Opinion Date: 06/16/2011
Subsequent History: 131 S.Ct. 2394; 180 L.Ed.2d 310

A child’s age is a relevant factor to consider in determining whether the child is “in custody” warranting Miranda warnings. The majority opinion by Justice Sotomayor adds to the Miranda equation a requirement that if an officer knows a suspect’s young age, or it is apparent, the officer must take that into account in the “custody” requirement such that a Miranda rights warning must be given. A uniformed officer assigned to the school removed 13-year-old J.D.B. from his classroom and escorted him to a closed-door room where police and school administrators questioned him. There were no Miranda warnings, he was not advised that he was free to leave, and he was not given an opportunity to call his grandmother or legal guardian. Once threatened with juvenile detention, he made a confession and only then was he told that he could refuse to answer questions and he was free to leave. J.D.B.’s age would have affected how a “reasonable person” in his position would have objectively perceived his status and his ability to leave. Justice Alito filed a dissenting opinion, which was joined by the Chief Justice and Justices Scalia and Thomas.