US SUPREME COURT DECISIONS
J. D. B. v. North Carolina
Opinion Summary:
J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time.SYLLABUS
OCTOBER TERM, 2010
J. D. B. V. NORTH CAROLINA
SUPREME COURT OF THE UNITED STATES
J. D. B. v. NORTH CAROLINA
certiorari to the supreme court of north carolina
No. 09–11121. Argued March 23, 2011—Decided June 16, 2011
Police stopped and questioned petitioner J. D. B., a 13-year-old, seventh-grade student, upon seeing him near the site of two home break-ins. Five days later, after a digital camera matching one of the stolen items was found at J. D. B.’s school and seen in his possession, Investigator DiCostanzo went to the school. A uniformed police officer on detail to the school took J. D. B. from his classroom to a closed-door conference room, where police and school administrators questioned him for at least 30 minutes. Before beginning, they did not give him Miranda warnings or the opportunity to call his grandmother, his legal guardian, nor tell him he was free to leave the room. He first denied his involvement, but later confessed after officials urged him to tell the truth and told him about the prospect of juvenile detention. DiCostanzo only then told him that he could refuse to answer questions and was free to leave. Asked whether he understood, J. D. B. nodded and provided further detail, including the location of the stolen items. He also wrote a statement, at DiCostanzo’s request. When the school day ended, he was permitted to leave to catch the bus home. Two juvenile petitions were filed against J. D. B., charging him with breaking and entering and with larceny. His public defender moved to suppress his statements and the evidence derived therefrom, arguing that J. D. B. had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. The trial court denied the motion. J. D. B. entered a transcript of admission to the charges, but renewed his objection to the denial of his motion to suppress. The court adjudicated him delinquent, and the North Carolina Court of Appeals and State Supreme Court affirmed. The latter court declined to find J. D. B.’s age relevant to the determination whether he was in police custody:chanrobles.com-red
Held: A child’s age properly informs Miranda’s custody analysis. Pp. 5–18:chanrobles.com-red
(a) Custodial police interrogation entails “inherently compelling pressures,” Miranda v. Arizona, 384 U. S. 436, 467, that “can induce a frighteningly high percentage of people to confess to crimes they never committed,” Corley v. United States, 556 U. S. ___, ___. Recent studies suggest that risk is all the more acute when the subject of custodial interrogation is a juvenile. Whether a suspect is “in custody” for Miranda purposes is an objective determination involving two discrete inquires: “first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a reasonable person have felt he or she was at liberty to terminate the interrogation and leave.” Thompson v. Keohane, 516 U. S. 99, 112 (footnote omitted). The police and courts must “examine all of the circumstances surrounding the interrogation,” Stansbury v. California, 511 U. S. 318, 322, including those that “would have affected how a reasonable person” in the suspect’s position “would perceive his or her freedom to leave,” id., at 325. However, the test involves no consideration of the particular suspect’s “actual mindset.” Yarborough v. Alvarado, 541 U. S. 652, 667. By limiting analysis to objective circumstances, the test avoids burdening police with the task of anticipating each suspect’s idiosyncrasies and divining how those particular traits affect that suspect’s subjective state of mind. Berkemer v. McCarty, 468 U. S. 420, 430–431. Pp. 5–8:chanrobles.com-red
(b) In some circumstances, a child’s age “would have affected how a reasonable person” in the suspect’s position “would perceive his or her freedom to leave.” Stansbury, 511 U. S., at 325. Courts can account for that reality without doing any damage to the objective nature of the custody analysis. A child’s age is far “more than a chronological fact.” Eddings v. Oklahoma, 455 U. S. 104, 115. It is a fact that “generates commonsense conclusions about behavior and perception,” Alvarado, 541 U. S., at 674, that apply broadly to children as a class. Children “generally are less mature and responsible than adults,” Eddings, 455 U. S., at 115; they “often lack the experience, perspective, and judgment to recognize and avoid choices that could be detrimental to them,” Bellotti v. Baird, 443 U. S. 622, 635; and they “are more vulnerable or susceptible to … outside pressures” than adults, Roper v. Simmons, 543 U. S. 551, 569. In the specific context of police interrogation, events that “would leave a man cold and unimpressed can overawe and overwhelm a” teen. Haley v. Ohio, 332 U. S. 596, 599. The law has historically reflected the same assumption that children characteristically lack the capacity to exercise mature judgment and possess only an incomplete ability to understand the world around them. Legal disqualifications on children as a class—e.g., limitations on their ability to marry without parental consent—exhibit the settled understanding that the differentiating characteristics of youth are universal:chanrobles.com-red
Given a history “replete with laws and judicial recognition” that children cannot be viewed simply as miniature adults, Eddings, 455 U. S., at 115–116, there is no justification for taking a different course here. So long as the child’s age was known to the officer at the time of the interview, or would have been objectively apparent to a reasonable officer, including age as part of the custody analysis requires officers neither to consider circumstances “unknowable” to them, Berkemer, 468 U. S., at 430, nor to“ ‘ “anticipat[e] the frailties or idiosyncrasies” of the particular suspect being questioned.” ’ ” Alvarado, 541 U. S., at 662. Precisely because childhood yields objective conclusions, considering age in the custody analysis does not involve a determination of how youth affects a particular child’s subjective state of mind. In fact, were the court precluded from taking J. D. B.’s youth into account, it would be forced to evaluate the circumstances here through the eyes of a reasonable adult, when some objective circumstances surrounding an interrogation at school are specific to children. These conclusions are not undermined by the Court’s observation in Alvarado that accounting for a juvenile’s age in the Miranda custody analysis “could be viewed as creating a subjective inquiry,” 541 U. S., at 668. The Court said nothing about whether such a view would be correct under the law or whether it simply merited deference under the Antiterrorism and Effective Death Penalty Act of 1996, 110 Stat. 1214. So long as the child’s age was known to the officer, or would have been objectively apparent to a reasonable officer, including age in the custody analysis is consistent with the Miranda test’s objective nature. This does not mean that a child’s age will be a determinative, or even a significant, factor in every case, but it is a reality that courts cannot ignore. Pp. 8–14:chanrobles.com-red
(c) Additional arguments that the State and its amici offer for excluding age from the custody inquiry are unpersuasive. Pp. 14–18:chanrobles.com-red
(d) On remand, the state courts are to address the question whether J. D. B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including J. D. B.’s age at the time. P. 18:chanrobles.com-red
363 N. C. 664, 686 S. E. 2d 135, reversed and remanded:chanrobles.com-red
Sotomayor, J., delivered the opinion of the Court, in which Kennedy, Ginsburg, Breyer, and Kagan, JJ., joined. Alito, J., filed a dissenting opinion, in which Roberts, C.J., and Scalia and Thomas, JJ., joined.
