J. D. B. v. North Carolina, 131 S. Ct. 2394

J. D. B., a 13-year-old student, was removed from class and police questioned for 30–45 minutes in a school conference room without Miranda warnings or a chance to contact his guardian.
This was the second police interview in a week; prior questioning occurred near the crime scene and involved the guardian, grandmother, and aunt.
A digital camera tied to the break-ins was found at J. D. B.’s middle school and in his possession, prompting investigator DiCostanzo to question him at the school with school staff present.
The interrogation occurred in a closed-door room with both police officers and school administrators; J. D. B. was not informed he could leave and was not warned about rights at the outset.
Two juvenile petitions for breaking and entering and larceny were filed; the trial court denied suppression, finding no custody and voluntary statements, and J. D. B. admitted to the charges.
North Carolina appellate courts disagreed on whether age should inform Miranda custody; the state supreme court held age was not to be considered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is a juvenile’s age a relevant factor in the Miranda custody analysis?	J. D. B. argues age informs custody and should be considered.	State contends age is irrelevant to custody analysis and should be an objective fact only.	Yes; age may inform custody when known or reasonably apparent.
Does incorporating age preserve the objective character of the custody test?	Age can be included without undermining objectivity; it reflects commonsense realities of youth.	Age would undermine the objective, one-size-fits-all test and confuse the custody standard.	Age can be incorporated as an objective consideration when known or apparent.
Would adding age to custody analysis threaten Miranda’s clarity and administrability?	Including age is a manageable, limited adjustment that aligns with predictable police guidance.	Expanding custody analysis to include age will erode Miranda’s clarity and require case-specific judgments.	The court rejects that this will erode clarity; remand to determine custody with age considerations.

Miranda v. Arizona, 384 U.S. 436 (1966) (establishes Miranda warnings and custody framework)
Oregon v. Mathiason, 429 U.S. 492 (1977) (custodial vs. non-custodial interrogation distinction)
Stansbury v. California, 511 U.S. 318 (1994) (objective custody test; disregard subjective mindset)
Berkemer v. McCarty, 468 U.S. 420 (1984) (traffic-stop custody context; objective factors)
California v. Beheler, 463 U.S. 1121 (1983) (Beheler & Mathiason as non-custody examples; objective inquiry)
Alvarado v. Dyson, 541 U.S. 652 (2004) (age not ordinarily considered in custody; AEDPA context)
Dickerson v. United States, 530 U.S. 428 (2000) (Miranda protections and coercion concerns)
Keohane v. Thompson, 516 U.S. 99 (1995) (objective custody test; factors for custody determination)