J.D.B. v. North Carolina

131 S.Ct. 2394 (2011)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

J. D. B. (D) was a 13-year-old, seventh-grade student. Two home break-ins occurred, and various items were stolen. Police stopped and questioned D after he was seen behind a residence in the neighborhood where the crimes occurred. Police later learned that a digital camera matching the description of one of the stolen items had been found at D’s middle school and seen in D’s possession. Officers went to the school, and upon arrival, informed the uniformed police officer on detail to the school (a so-called school resource officer), the assistant principal, and an administrative intern that he was there to question D. about the break-ins. They asked the school administrators to verify D’s date of birth, address, and parent contact information from school records, but no one contacted D’s grandmother. A uniformed officer interrupted D.’s afternoon social studies class, removed D from the classroom, and escorted him to a school conference room. D was met by a detective, the assistant principal, and the administrative intern. The door to the conference room was closed. D was questioned for the next 30 to 45 minutes. Prior to the commencement of questioning, D was given neither Miranda warnings nor the opportunity to speak to his grandmother. Nor was he informed that he was free to leave the room. D started to break down and asked incriminating questions. After learning of the prospect of juvenile detention, D confessed that he and a friend were responsible for the break-ins. Only then was D informed that he could refuse to answer the investigator’s questions and that he was free to leave. Asked whether he understood, D nodded and provided further detail, including information about the location of the stolen items. D wrote a statement, at the detective's request. When the bell rang indicating the end of the school day, D was allowed to leave to catch the bus home. Juvenile petitions were filed against D. The public defender moved to suppress his statements, and the evidence derived therefrom, arguing that suppression was necessary because D had been “interrogated by police in a custodial setting without being afforded Miranda warnings.” The trial court denied the motion, deciding that D was not in custody at the time of the schoolhouse interrogation and that his statements were voluntary. A divided panel of the North Carolina Court of Appeals affirmed. The Supreme Court granted certiorari to determine whether the Miranda custody analysis includes consideration of a juvenile suspect’s age.