In re D.A.C., 741 S.E.2d 378

Juvenile D.A.C. appeals from orders adjudicating him delinquent for injury to real and personal property and placing him on probation.
Officers confronted Juvenile outside his home after gunfire was traced to the home across the street.
Mother spoke with officers; Juvenile admitted to firing after being asked if he did so.
Officers did not Miranda Warnings or 7B-2101 warnings; Juvenile was not arrested or handcuffed.
Trial court denied the suppression of the oral statement but suppressed a written statement; Juvenile admitted to offenses and adjudication followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Juvenile in custody for Miranda purposes?	Juvenile argues custodial interrogation triggered warnings.	State asserts no custodial custody given open yard setting and parental presence.	Not in custody; custodial interrogation not established.
Whether oral admission was admissible without Miranda/7B-2101 warnings.	Admissibility supported by non-custodial questioning and lack of coercion.	Admission obtained during custodial interrogation without warnings should be excluded.	Oral admission admissible; not the product of custodial interrogation.

In re W.R., 363 N.C. 244 (N.C. 2009) (Miranda/7B-2101 apply only to custodial interrogations)
J.D.B. v. North Carolina, 131 S. Ct. 2394 (U.S. 2011) (juvenile age relevant to custody analysis)
State v. Crudup, 157 N.C. App. 657 (N.C. App. 2003) (factors for custody assessment)
Stansbury v. California, 511 U.S. 318 (U.S. 1994) (random factors in custody determination)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (requires warnings for custodial interrogation)
In re Butts, 157 N.C. App. 609 (N.C. App. 2003) (threshold custody inquiry for 7B-2101 analysis)
State v. Clay, 39 N.C. App. 150 (N.C. App. 1978) (custody factors in interrogation)
State v. Morrell, 108 N.C. App. 465 (N.C. App. 1993) (agency of interrogation and admissibility)
State v. Nations, 319 N.C. 329 (N.C. 1987) (admissibility of statements when not warned)