juveniles

J.D.B. v. North Carolina

Issues

Does the age of an individual questioned by police affect whether that individual is in custody and must receive Miranda warnings?

Court below

Supreme Court of North Carolina

Petitioner J.D.B. was a thirteen-year-old boy suspected of being involved in two break-ins. The police questioned him while he was at school without giving him a Miranda warning, and J.D.B. made incriminating statements. At his trial, J.D.B. moved to suppress those statements, arguing that he had been subjected to custodial interrogation under Miranda v. Arizona. Specifically, J.D.B. argued that a court should take account of his age when determining whether he was in custody. The North Carolina trial court and appellate courts all held that J.D.B. was not in custody for purposes of Miranda and allowed the statements into evidence. J.D.B. was convicted, placed on 12 months’ probation, and ordered to pay restitution. J.D.B. appealed to the Supreme Court, arguing that age should be a factor in determining whether he was in custody for Miranda purposes. North Carolina contends that age is a subjective factor and should not be part of the objective custody inquiry. This case will determine what personal characteristics should be considered when determining whether a subject is in custody, and, therefore, whether a Miranda warning is necessary prior to questioning.

Questions as Framed for the Court by the Parties

Whether a court may consider a juvenile's age in a Miranda custody analysis in evaluating the totality of the circumstances and determining whether a reasonable person in the juvenile's position would have felt he or she was not free to terminate police questioning and leave?

On September 24, 2005, police spotted and interviewed Petitioner J.D.B. in the vicinity of two break-ins in Chapel Hill, North Carolina. See In re J.D.B., 686 S.E.2d 135, 136 (N.C.