131 S. Ct. 2394
U.S.2011Background
- J. D. B. was a 13-year-old middle-school student questioned by police without Miranda warnings.
- Questioning occurred after he was removed from class and escorted to a closed conference room by school and police personnel.
- It was the second interview in a week; earlier police questioned him near the scene of the burglaries.
- The interview occurred without guardianship contact or warnings; he was not told he could leave.
- Two juvenile petitions were filed; the trial court found no custody and the statements voluntary; NC Supreme Court disagreed on custody analysis.
- The Supreme Court granted certiorari to decide whether a juvenile’s age informs the Miranda custody analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a juvenile’s age is a relevant custody factor | J. D. B.'s age should inform custody | State asserts age is irrelevant to custody | Yes, age informs custody analysis |
| Whether J. D. B. was in Miranda custody during questioning | Interrogation occurred in a school setting with authorities present | Lack of warnings suggests custody was present | To be determined on remand given age factor |
| Whether inclusion of age in custody analysis affects Miranda safeguards | Age helps protect juveniles from coercive interrogation | Age would undermine clarity of custody rule | Remanded to resolve custody with age considered |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (establishes Miranda warnings and custody framework)
- Oregon v. Mathiason, 429 U.S. 492 (U.S. 1977) (cookies: custodial interrogation risk; not necessarily custody)
- Dickerson v. United States, 530 U.S. 428 (U.S. 2000) (Miranda safeguards reception and voluntariness baseline)
- Stansbury v. California, 511 U.S. 318 (U.S. 1994) (objective custody test; focus on surrounding circumstances)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (custody defined by restraint on freedom of movement; objective standard)
- Alvarado v. Duchesne, 541 U.S. 652 (U.S. 2004) (recognizes custody evaluation as objective; age context discussed)