B.A. v. State, 100 N.E.3d 225

A pink‑marker bomb threat was found in a middle‑school bathroom; school resource officers identified two suspects, including 13‑year‑old B.A.
On the morning after the threat, officers and the vice‑principal removed B.A. from his bus and escorted him to the vice‑principal’s office for questioning.
Three uniformed school resource officers remained in the room or between B.A. and the door during a roughly 15‑minute interview led by the vice‑principal.
Officers administered a handwriting comparison exercise and prompted B.A. (e.g., “Come on, man, just‑just tell the truth”), after which B.A. admitted the threat and told his mother it was a joke.
After the interview B.A. was suspended, arrested by the officers, and detained; he moved to suppress his statements as taken in custodial interrogation without Miranda warnings and without complying with Indiana’s juvenile waiver statute.
The juvenile court admitted the statements and adjudicated B.A. delinquent; the Court of Appeals affirmed, and the Indiana Supreme Court granted transfer and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miranda applies—was B.A. in custodial interrogation at school?	B.A.: under totality, a reasonable 13‑year‑old would not feel free to leave given uniformed officers, lack of parent, officers between him and door.	State: officers’ presence noncoercive and didn’t directly question B.A.; interview was educational/disciplinary in nature.	Court: B.A. was in police custody under the totality of circumstances—custodial interrogation applied.
Whether officers’ words/actions constituted interrogation under Miranda/Innis	B.A.: officers’ handwriting test and coaxing were likely to elicit incriminating responses.	State: officers did not expressly question; vice‑principal led questioning for educational purposes.	Court: officer‑prepared handwriting exercise and Lyday’s exhortation were police interrogation under Innis.
Whether Miranda warnings or juvenile‑waiver protections were required and waived	B.A.: Miranda and Indiana juvenile waiver statute applied; no valid waiver obtained.	State: no Miranda required because this was school discipline/administrative questioning.	Court: Miranda and juvenile waiver statute applied; statements should have been suppressed.
Remedy for admission of unwarned custodial statements	B.A.: suppress statements and reverse adjudication.	State: challenged suppression but lacked persuasive custody/interrogation showing.	Court: suppressed statements, reversed delinquency adjudications, remanded.

Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings for custodial interrogation)
J.D.B. v. North Carolina, 564 U.S. 261 (juvenile age is relevant to custody analysis)
Howes v. Fields, 565 U.S. 499 (custody test: whether circumstances present coercive pressures like station‑house questioning)
Rhode Island v. Innis, 446 U.S. 291 (interrogation includes words/actions officers should know likely to elicit incriminating response)
Berkemer v. McCarty, 468 U.S. 420 (Miranda custody analysis under totality of circumstances)
In re Gault, 387 U.S. 1 (juveniles require special procedural protections)
New York v. Quarles, 467 U.S. 649 (public safety exception to Miranda)
Vernonia Sch. Dist. 47J v. Acton, 515 U.S. 646 (students retain constitutional rights at school)