In re N.J., 221 N.C. App. 427

Officers Tidwell and Kimbell confronted Juvenile and three others trespassing at a Durham Housing Authority complex.
Tidwell searched Juvenile with consent; Juvenile admitted marijuana in his jeans.
Kimbell patted down the other three; no contraband found on them.
Tidwell found thirteen bagged items inside a toboggan; seven bags tested positive for marijuana.
Juvenile was charged with possession of a controlled substance with intent to manufacture, sell, or deliver; suppression motion was denied.
Trial court did not issue findings of fact or conclusions of law nor rationale for denying the suppression motion; admission hearing occurred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the suppress motion complied with §15A-977(f) requirements	Juvenile—trial court failed to provide findings or rationale	State—statutory requirements apply; court can rely on denial	Remand for proper findings and rationale
Whether failure to inform most restrictive disposition invalidates admission	Juvenile argues lack of required personal informing	State contends admission valid notwithstanding omission	Adjudication and admission vacated and remanded for proper procedure
Effect of procedural defects on admissibility of statements	Statements should be suppressed if custody and Miranda issues unresolved	State argues admissions were voluntary	Remand to determine suppression with proper findings of fact and law

State v. Baker, 702 S.E.2d 825 (N.C. App. 2010) (mandatory findings under 15A-977(f) when denial of suppression lacks bench rationale and no material conflicts)
State v. Norris, 335 S.E.2d 764 (N.C. Supreme Court 1985) (juvenile protections mapped to adult standards)
In re Stallings, 350 S.E.2d 327 (N.C. 1986) (precedent on juvenile procedural standards)
State v. Williams, 673 S.E.2d 394 (N.C. App. 2009) (context for findings of fact and suppression review)