J.D.B. v. North Carolina
Encyclopedia
J.D.B. v. North Carolina, No. 09-11121
(2011), was a recent case in which the Supreme Court of the United States
held that a child’s age properly informs the Miranda
custody analysis. The petitioner J.D.B. was a 13 year old student enrolled in special education
classes whom police had suspected of committing two robberies. A police investigator visited J.D.B. at school, where he was interrogated by the investigator, a uniformed police officer, and school officials. J.D.B. subsequently confessed to his crimes and was convicted. J.D.B. was not given a Miranda warning during the interrogation, nor an opportunity to contact his legal guardian. During the trial, attempts to suppress the statements given by J.D.B. because he was not given a Miranda warning were denied on the grounds that J.D.B. was not in police custody."In The Matter of JDB", North Carolina Supreme Court, December 11, 2010, accessed June 18th, 2011 After examining the lower court's reasoning, the Supreme Court found that J.D.B.'s age should have been considered in the custody analysis. The Court remanded the case and instructed the lower court to make a new finding on custody while taking age into account.
, North Carolina
when he was taken out of class by a uniformed police officer and questioned. J. D. B. had been questioned previously by the police when they saw him in the neighborhood where two home break-ins had occurred. After questioning J. D. B. the first time, police learned that a digital camera matching the description of a stolen item had been seen in the possession of J. D. B. This prompted the juvenile investigator assigned to the case to go to the school to question J. D. B. Upon arriving at the school, the investigator informed the uniformed police officer on detail to the school and members of the school's administration. The uniformed officer interrupted the class J. D. B. was in and escorted him to a school conference room, where J. D. B. was subsequently questioned by the investigator, police officer, and members of the schools administration for 30 to 45 minutes. Prior to the questioning, J. D. B. was neither given Miranda warnings nor an opportunity to speak to his legal guardian. Nor was he informed that he was free to leave the room.
Initially J. D. B. denied any wrongdoing. After being confronted with the stolen camera and after the urging of a school administrator, J. D. B. confessed to the break-ins. It was at this point after the confession that the investigator informed J. D. B. that he could refuse to answer questions and that he was free to leave. J. D. B. indicated that he understood and then proceeded to provide further details about the crime, including the location of the stolen property. J. D. B. wrote a statement at the investigators request and then he was allowed to leave to catch the bus home.
to determine whether the Miranda custody analysis includes consideration of a juvenile suspect’s age.
Sonia Sotomayor
wrote the opinion for the Court, which commanded a majority only in part.
The Court held that a child's age properly informs the Miranda custody analysis.
was also cited, where the Court wrote that a child's age "generates commonsense conclusions about behavior and perception". Finally, the Court pointed out that the law reflects the idea that a child's judgement is not the same as an adult's, in the form of legal disqualifications on children as a class (e.g. limitations on a child's ability to marry without parental consent).
The Court wrote that consideration of age involved no consideration of the specific mindset of the individual. Rather, the Court held that age is an objective fact that affects how a reasonable person would perceive his or her freedom to leave.
Associate Justice
Samuel Alito
wrote a dissenting opinion for four Justices. The primary objection of the dissent was that the ruling of majority was inconsistent with one of the main justifications for the Miranda rule: the need for a clear rule that is easily applied in all cases. Alito argued the decision shifted custody determination from a simple test to an inquiry that must account for individualized characteristics. Alito emphasized that age is not the only characteristic that may affect a subject under interrogation and that in future cases the court will be tasked with adding additional characteristics to custody determination or by "arbitrarily distinguishing a suspect's age from other personal characteristics".
, American Bar Association
, and the National Association of Criminal Defense Lawyers
were among the organizations that filed amicus briefs in support of J.D.B. The attorneys general
of 30 states
and 2 unincorporated territories
filed an amicus brief in support of North Carolina.
The ruling was characterized by Steven Drizin, professor at Northwestern University School of Law
, characterized the ruling as "huge". The Juvenile Law Center called the ruling a "landmark decision".
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2011), was a recent case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that a child’s age properly informs the Miranda
Miranda warning
The Miranda warning is a warning given by police in the United States to criminal suspects in police custody before they are interrogated to preserve the admissibility of their statements against them in criminal proceedings. In Miranda v...
custody analysis. The petitioner J.D.B. was a 13 year old student enrolled in special education
Special education
Special education is the education of students with special needs in a way that addresses the students' individual differences and needs. Ideally, this process involves the individually planned and systematically monitored arrangement of teaching procedures, adapted equipment and materials,...
classes whom police had suspected of committing two robberies. A police investigator visited J.D.B. at school, where he was interrogated by the investigator, a uniformed police officer, and school officials. J.D.B. subsequently confessed to his crimes and was convicted. J.D.B. was not given a Miranda warning during the interrogation, nor an opportunity to contact his legal guardian. During the trial, attempts to suppress the statements given by J.D.B. because he was not given a Miranda warning were denied on the grounds that J.D.B. was not in police custody."In The Matter of JDB", North Carolina Supreme Court, December 11, 2010, accessed June 18th, 2011 After examining the lower court's reasoning, the Supreme Court found that J.D.B.'s age should have been considered in the custody analysis. The Court remanded the case and instructed the lower court to make a new finding on custody while taking age into account.
Police Investigation
J. D. B. was a 13-year-old student attending Smith Middle School in Chapel HillChapel Hill, North Carolina
Chapel Hill is a town in Orange County, North Carolina, United States and the home of the University of North Carolina at Chapel Hill and UNC Health Care...
, North Carolina
North Carolina
North Carolina is a state located in the southeastern United States. The state borders South Carolina and Georgia to the south, Tennessee to the west and Virginia to the north. North Carolina contains 100 counties. Its capital is Raleigh, and its largest city is Charlotte...
when he was taken out of class by a uniformed police officer and questioned. J. D. B. had been questioned previously by the police when they saw him in the neighborhood where two home break-ins had occurred. After questioning J. D. B. the first time, police learned that a digital camera matching the description of a stolen item had been seen in the possession of J. D. B. This prompted the juvenile investigator assigned to the case to go to the school to question J. D. B. Upon arriving at the school, the investigator informed the uniformed police officer on detail to the school and members of the school's administration. The uniformed officer interrupted the class J. D. B. was in and escorted him to a school conference room, where J. D. B. was subsequently questioned by the investigator, police officer, and members of the schools administration for 30 to 45 minutes. Prior to the questioning, J. D. B. was neither given Miranda warnings nor an opportunity to speak to his legal guardian. Nor was he informed that he was free to leave the room.
Initially J. D. B. denied any wrongdoing. After being confronted with the stolen camera and after the urging of a school administrator, J. D. B. confessed to the break-ins. It was at this point after the confession that the investigator informed J. D. B. that he could refuse to answer questions and that he was free to leave. J. D. B. indicated that he understood and then proceeded to provide further details about the crime, including the location of the stolen property. J. D. B. wrote a statement at the investigators request and then he was allowed to leave to catch the bus home.
Trial and Appeal
Two juvenile petitions were filed against J. D. B. Each alleged one count of latency and one count of breaking and entering. J. D. B.'s public defender argued that J. D. B. had been interrogated by police in a custodial setting with being afforded Miranda warnings and moved to suppress J. D. B.'s statements and the evidenced derived therefrom. The trial court decided that J. D. B. was not in custody and the motion was denied. The North Carolina Supreme Court affirmed with a divided pannel, "declin[ing] to extend the test for custody to include consideration of the age... of an individual subjected to questioning by police". The Supreme Court granted certiorariCertiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
to determine whether the Miranda custody analysis includes consideration of a juvenile suspect’s age.
Opinion of the Court
Associate JusticeAssociate Justice
Associate Justice or Associate Judge is the title for a member of a judicial panel who is not the Chief Justice in some jurisdictions. The title "Associate Justice" is used for members of the United States Supreme Court and some state supreme courts, and for some other courts in Commonwealth...
Sonia Sotomayor
Sonia Sotomayor
Sonia Maria Sotomayor is an Associate Justice of the Supreme Court of the United States, serving since August 2009. Sotomayor is the Court's 111th justice, its first Hispanic justice, and its third female justice....
wrote the opinion for the Court, which commanded a majority only in part.
The Court held that a child's age properly informs the Miranda custody analysis.
Relevancy of Age
The Court underscored the dangers of not applying age to the custody analysis, writing: "to hold... that a child's age is never relevant to whether a suspect has been taken into custody— and thus to ignore the very real differences between children and adults— would be to deny children the full scope of the procedural safeguards that Miranda guarantees to adults". The opinion cited Stansbury v. California where the Court held that a child's age "would have affected how a reasonable person" in the suspect's position "would perceive his or her freedom to leave". Yarborough v. AlvaradoYarborough v. Alvarado
Yarborough v. Alvarado, No. 02-1684 , was a case in which the Supreme Court of the United States held that a state court considered the proper factors and reached a reasonable conclusion that a minor was not in custody for Miranda purposes during his police interview, despite the fact that the...
was also cited, where the Court wrote that a child's age "generates commonsense conclusions about behavior and perception". Finally, the Court pointed out that the law reflects the idea that a child's judgement is not the same as an adult's, in the form of legal disqualifications on children as a class (e.g. limitations on a child's ability to marry without parental consent).
Miranda as an Objective Test
The Court placed emphasis on the fact that age is an objective circumstance and including it in a custody analysis does not place an undue burden on the police. The Court has repeatedly emphasized that the custody analysis is an objective test. In Thompson v. Keohane the Court wrote that:The Court wrote that consideration of age involved no consideration of the specific mindset of the individual. Rather, the Court held that age is an objective fact that affects how a reasonable person would perceive his or her freedom to leave.
Dissent
Associate Justice
Associate Justice or Associate Judge is the title for a member of a judicial panel who is not the Chief Justice in some jurisdictions. The title "Associate Justice" is used for members of the United States Supreme Court and some state supreme courts, and for some other courts in Commonwealth...
Samuel Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
wrote a dissenting opinion for four Justices. The primary objection of the dissent was that the ruling of majority was inconsistent with one of the main justifications for the Miranda rule: the need for a clear rule that is easily applied in all cases. Alito argued the decision shifted custody determination from a simple test to an inquiry that must account for individualized characteristics. Alito emphasized that age is not the only characteristic that may affect a subject under interrogation and that in future cases the court will be tasked with adding additional characteristics to custody determination or by "arbitrarily distinguishing a suspect's age from other personal characteristics".
Impact of the Case
The case attracted differing opinions within the legal community. The American Civil Liberties UnionAmerican Civil Liberties Union
The American Civil Liberties Union is a U.S. non-profit organization whose stated mission is "to defend and preserve the individual rights and liberties guaranteed to every person in this country by the Constitution and laws of the United States." It works through litigation, legislation, and...
, American Bar Association
American Bar Association
The American Bar Association , founded August 21, 1878, is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. The ABA's most important stated activities are the setting of academic standards for law schools, and the formulation...
, and the National Association of Criminal Defense Lawyers
National Association of Criminal Defense Lawyers
The National Association of Criminal Defense Lawyers is an American criminal defense organization. Their stated mission is to "Ensure justice and due process for persons accused of crime. Foster the integrity, independence and expertise of the criminal defense profession...
were among the organizations that filed amicus briefs in support of J.D.B. The attorneys general
State Attorney General
The state attorney general in each of the 50 U.S. states and territories is the chief legal advisor to the state government and the state's chief law enforcement officer. In some states, the attorney general serves as the head of a state department of justice, with responsibilities similar to those...
of 30 states
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
and 2 unincorporated territories
Unincorporated territories of the United States
Unincorporated territory is a legal term of art in United States law denoting an area controlled by the government of the United States, but which is not a part of the United States proper ....
filed an amicus brief in support of North Carolina.
The ruling was characterized by Steven Drizin, professor at Northwestern University School of Law
Northwestern University School of Law
The Northwestern University School of Law is a private American law school in Chicago, Illinois. The law school was founded in 1859 as the Union College of Law of the Old University of Chicago. The first law school established in Chicago, it became jointly controlled by Northwestern University in...
, characterized the ruling as "huge". The Juvenile Law Center called the ruling a "landmark decision".