B.A. v. State of Indiana, 2017 Ind. App. LEXIS 138

Jan. 8, 2016: Pink-marker bomb threat found on Decatur Middle School boys’ restroom wall; school police investigated and identified B.A., a 13‑year‑old, as a suspect via video review.
On Feb. 8, 2016 school administrators and school resource officers removed B.A. from his bus and brought him to the vice principal Remaly’s L‑shaped office for questioning; multiple officers were present in the room at various positions.
Remaly led the interview; B.A. denied the allegation, was given a handwriting ‘‘scenario sample’’ (Officer Tutsie explained how to copy it at Remaly’s direction), copied it, and Remaly compared it to the wall writing.
After comparison Remaly confronted B.A., who cried and said “I don’t know, I’m sorry” and that it was a joke; Remaly suspended B.A. pending expulsion and called the parent; law enforcement later decided to arrest him.
State filed juvenile delinquency petition for false reporting (level 6 felony if adult) and institutional criminal mischief (class A misdemeanor if adult); B.A. moved to suppress his statements as obtained in violation of Miranda and the juvenile‑waiver statute; the juvenile court denied the motion and entered true findings; appeal followed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (B.A.)	Held
Whether the juvenile court abused its discretion by admitting B.A.’s statements—i.e., whether the questioning was custodial interrogation requiring Miranda warnings and compliance with the juvenile waiver statute	The questioning was school‑disciplinary in nature, led by Vice Principal Remaly to protect school safety; officers’ presence was peripheral (one instruction and assistance with the handwriting sample) and did not transform the meeting into custodial interrogation	Officers drove the investigation, escorted B.A. from the bus, several officers were present in the room, an officer handed and instructed on the handwriting sample, and B.A. (13) was not free to leave—so Miranda and juvenile waiver protections should have applied	Court affirmed: questioning was led by the school administrator for an educational purpose; officers’ role was minimal/peripheral; under the totality of circumstances a reasonable person in B.A.’s position was not in Miranda custody, so statements were admissible

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes that statements from custodial interrogation are inadmissible absent Miranda warnings)
Innis v. Rhode Island, 446 U.S. 291 (1980) (defines "interrogation" to include police words or actions reasonably likely to elicit incriminating response)
J.D.B. v. North Carolina, 564 U.S. 261 (2011) (a child’s age may be considered in the custody analysis when known or objectively apparent)
Stansbury v. California, 511 U.S. 318 (1994) (police officers’ undisclosed investigative plans do not determine custody; custody is based on how a reasonable person in the suspect’s position would view the situation)
S.G. v. State, 956 N.E.2d 668 (Ind. Ct. App. 2011) (school‑questioning/custody framework: principal‑led questioning with passive officer presence may be noncustodial; officer presence can render questioning custodial in some circumstances)
C.D. v. State, 947 N.E.2d 1018 (Ind. Ct. App. 2011) (school administrator’s detention for educational purposes and officer assistance at administrator’s request did not convert the encounter into custodial interrogation)