J.D.B. v. North Carolina
Citation and Court
564 U.S. 261 (2011) — Supreme Court of the United States
Facts
J.D.B. was a 13-year-old middle school student who was pulled out of class and brought to a conference room where a police investigator questioned him about break-ins without reading him Miranda warnings. He eventually confessed. The question was whether his age was relevant to whether he was “in custody” for Miranda purposes.
Issue
Must a child’s age be taken into account in the Miranda custody analysis when the child’s age was known or objectively apparent to the officer?
Holding
Yes; a child’s age is a relevant, objective factor that must be considered in determining whether a reasonable person in the suspect’s position would feel free to terminate the interrogation and leave.
Rule / Doctrine
The Miranda custody test is an objective inquiry asking whether a reasonable person in the suspect’s position would feel free to terminate the interrogation and leave. A child’s age, if known or objectively apparent to officers, is an objective circumstance that bears on this custody determination because children typically feel less free to walk away from police questioning than adults.
Significance
J.D.B. is the leading case on the intersection of juvenile status and Miranda custody, establishing that the objective custody test must account for age-specific vulnerabilities. It signals the Court’s recognition that the reasonable-person standard must be calibrated to the suspect’s relevant characteristics in the juvenile context.