Criminal Law: Miranda Warnings

Petitioner J.D.B., a 13 year-old student suspected of home break-ins, was questioned by the police at his school.  J.D.B. confessed to the crimes and was charged with breaking and entering, and larceny.  At trial, J.D.B’s public defender moved to suppress his statements on the grounds that the interrogation had been conducted in a “custodial setting” without a Miranda warning.  The trial court denied the motion, holding that J.D.B. was not in custody at the time of the interrogation. The North Carolina Court of Appeals and the Supreme Court of North Carolina affirmed the lower court’s decision. 

In J.D.B. v. North Carolina (09-11121), the Supreme Court split 5-4, holding that a minor’s age is a proper consideration in a custody analysis.  Writing for the majority, Justice Sotomayor noted that the custody analysis objectively determines whether a reasonable person would feel free to leave the interrogation in the given circumstances.   She argued that, because children lack the capacity to make the same reasoned decisions as adults would in similar circumstances, age must be a factor in applying this test.   In his dissent, Justice Alito argued that the majority’s decision was inconsistent with the perceived need for a clear, “one-size-fits-all reasonable person test” that can be applied in all cases.