J. D. B. v. North Carolina

A Miranda warning is an explanation of a suspect's rights that must be given by law enforcement before interrogation. It stems from the 1966 Miranda v. Arizona case, and is based primarily on the Fifth Amendment right against self-incrimination. If a defendant in custody is not notified of their rights via a Miranda warning, any confession they give may not be admissible in court.[1] If a defendant is not in police custody, however, police are free to question suspects without informing them of their rights, and their statements may still be admissible.[2]

J. D. B. was a 13-year-old student attending Smith Middle School in Chapel Hill, North Carolina when he was taken out of class by a uniformed police officer and questioned. J. D. B. had been questioned previously by the police when they saw him in the neighborhood where two home break-ins had occurred. After questioning J. D. B. the first time, police learned that a digital camera matching the description of a stolen item had been seen in the possession of J. D. B. This prompted the juvenile investigator assigned to the case to go to the school to question J. D. B. Upon arriving at the school, the investigator informed the uniformed police officer on detail at the school and members of the school's administration. The uniformed officer interrupted the class J. D. B. was in and escorted him to a school conference room, where J. D. B. was subsequently questioned by the investigator, police officer, and members of the school's administration for 30 to 45 minutes. Prior to the questioning, J. D. B. was neither given Miranda warnings nor an opportunity to speak to his legal guardian, nor was he informed that he was free to leave the room.

Initially J. D. B. denied any wrongdoing. After being confronted with the stolen camera and after the urging of a school administrator, J. D. B. confessed to the break-ins. It was at this point, after the confession, that the investigator informed J. D. B. that he could refuse to answer questions and that he was free to leave. J. D. B. indicated that he understood and then proceeded to provide further details about the crime, including the location of the stolen property. J. D. B. wrote a statement at the investigator's request. He was allowed to leave to catch the bus home.

Two juvenile petitions were filed against J. D. B. Each alleged one count of larceny and one count of breaking and entering. J. D. B.'s public defender moved to suppress J. D. B.'s statements and the evidence derived from them, arguing that J. D. B. had been interrogated in police custody without the required Miranda warnings. The trial court decided that J. D. B. was not in custody, and denied the motion. The North Carolina Supreme Court affirmed with a divided panel, "declin[ing] to extend the test for custody to include consideration of the age... of an individual subjected to questioning by police".[3]

The Supreme Court granted certiorari to determine whether the Miranda custody analysis includes consideration of a juvenile suspect’s age. The American Civil Liberties Union, American Bar Association, and the National Association of Criminal Defense Lawyers were among the organizations that filed amicus briefs in support of J. D. B. The attorneys general of 30 states and 2 unincorporated territories filed an amicus brief in support of North Carolina.[4]

The Court underscored the dangers of not applying age to the custody analysis, writing:

to hold... that a child's age is never relevant to whether a suspect has been taken into custody— and thus to ignore the very real differences between children and adults— would be to deny children the full scope of the procedural safeguards that Miranda guarantees to adults.[5]

The opinion cited Stansbury v. California, where the Court held that a child's age "would have affected how a reasonable person" in the suspect's position "would perceive his or her freedom to leave". Yarborough v. Alvarado was also cited, where the Court wrote that a child's age "generates commonsense conclusions about behavior and perception". Finally, the Court pointed out that the law reflects the idea that a child's judgment is not the same as an adult's, in the form of legal disqualifications on children as a class (e.g. limitations on a child's ability to marry without parental consent).

The Court placed emphasis on the fact that age is an objective circumstance and including it in a custody analysis does not place an undue burden on the police. The Court has repeatedly emphasized that the custody analysis is an objective test. In Thompson v. Keohane the Court wrote that:

Two discrete inquiries are essential to the determination: first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a reasonable person have felt he or she was at liberty to terminate the interrogation and leave. Once the scene is set and the players’ lines and actions are reconstructed, the court must apply an objective test to resolve the ultimate inquiry: was there a formal arrest or restraint on freedom of movement of the degree associated with formal arrest.

— Associate Justice Ruth Bader Ginsburg, Thompson v. Keohane[6]

The Court wrote that consideration of age involved no consideration of the specific mindset of the individual. Rather, the Court held that age is an objective factor that affects how a reasonable person would perceive his or her freedom to leave.

Justice Alito authored the opinion for the dissent.

Associate Justice Samuel Alito wrote a dissenting opinion for four Justices. The primary objection of the dissent was that the ruling of the majority was inconsistent with one of the main justifications for the Miranda rule: the need for a clear rule that is easily applied in all cases. Alito argued the decision shifted custody determination from a simple test to an inquiry that must account for individualized characteristics. Alito emphasized that age is not the only characteristic that may affect a subject under interrogation and that in future cases the court will be tasked with adding additional characteristics to custody determination or by "arbitrarily distinguishing a suspect's age from other personal characteristics".[5]