Juvenile Law Center filed two amicus briefs in the Supreme Court of the United States on behalf of J.D.B, a 13-year-old seventh grade middle school student who was removed from his classroom by four adults, including a uniformed police officer and school resource officer, and questioned in a closed school conference room about alleged delinquent activity off school grounds. The first brief was filed in support of J.D.B.’s petition for certiorari and the second on the merits after certiorari was granted.
J.D.B. was not given his Miranda warnings during the interrogation or prior to making any statements about his conduct. Juvenile Law Center argued that a youth’s age is relevant to the determination of whether a suspect is “in custody” for Miranda purposes, and thus that J.D.B. should have been given Miranda warnings.
The North Carolina Supreme Court rejected the argument that age is relevant to the determination of whether to issue Miranda warnings.
The Supreme Court of the United States, in an opinion authored by Justice Sotomayor, reversed the North Carolina Supreme Court.
The Supreme Court ruled that a child’s age must be considered by law enforcement in determining whether Miranda warnings need to be given to children during police interrogations. The Court held that so long a child’s age was known to the officer at the time of police questioning, or would have been objectively apparent to a reasonable officer, its inclusion in the custody analysis is consistent with the objective nature of that test.