J.D.B. v. North Carolina
Out of the Classroom and Into a Civics Lesson
In 1966, in the landmark case Miranda v. Arizona, the Supreme Court held that a person questioned by law enforcement officers after being "taken into custody or otherwise deprived of his freedom of action in any significant way" must first "be warned that he has a right to remain silent, that any statement he does make may be used as evidence against him, and that he has a right to the presence of any attorney, either retained or appointed." Statements made by a defendant when law enforcement has not complied with this rule may not be admitted as evidence of guilt in a criminal trial.
An officer's obligation to administer Miranda warnings attaches only where there has been such a restriction on a person's freedom as to render him "in custody." In determining whether an individual was in custody, a court must examine all the circumstances surrounding the interrogation in determining whether there was a "formal arrest or restraint of freedom of movement of the degree associated with a formal arrest."
Many Circuit Courts of Appeals have laid out a number of non-exclusive factors to consider in determining whether a defendant is in custody, such as: (1) the language or tone used when initially confronting or later questioning the suspect; (2) the physical surroundings or location of the questioning; (3) the duration of the interview; (4) the extent to which the defendant is confronted with evidence of guilt; and (5) the degree of pressure applied to detain the individual, including whether the officers brandished weapons or touched the suspect.
In J.D.B. v. North Carolina, the Supreme Court was asked to decide whether the age of a child subjected to police questioning is also relevant to this custody determination.
J.D.B. was a thirteen-year-old student in the seventh grade when a uniformed police officer on detail at the school escorted him from his social studies classroom to a conference room where two school administrators and another police officer were waiting. In the closed-door room, Police Investigator Joseph DiCostanzo questioned J.D.B. for thirty to forty-five minutes about some recent neighborhood break ins. Among the items reported stolen was a digital camera that had been found at the school and seen in J.D.B.'s possession.
J.D.B. first denied his involvement. However, after the investigator pressed him for additional details about his presence in the neighborhood after one of the break ins and confronted him with the stolen camera, and after the assistant principal urged him to tell the truth, J.D.B. asked whether he would "still be in trouble" if he returned the "stuff." Investigator DiCostanzo then warned J.D.B. that he may face juvenile detention. J.D.B. confessed. At that time, Investigator DiCostanzo told J.D.B. that he could refuse to answer questions and was free to leave. Asked whether he understood, J.D.B. nodded and provided further details, including the location of the stolen items. He also wrote a statement, at the investigator's request. When the school day ended, J.D.B. was permitted to leave.
The state of North Carolina charged J.D.B. with breaking and entering and larceny. The public defender who represented J.D.B. moved to suppress his statements and any evidence gathered as a result of those statements. The public defender argued on behalf of J.D.B. that J.D.B. was in custody at the time he was interrogated and that the police had failed to give him a Miranda warning. The state trial court ruled that J.D.B. was not in police custody and denied the motion to suppress the statements and evidence. The court adjudicated him delinquent, finding that J.D.B had violated criminal laws.
J.D.B.'s public defender disagreed and appealed first to the North Carolina Court of Appeals and then to the North Carolina Supreme Court. Both appellate courts agreed with the trial court. The North Carolina Supreme Court held that the test for custody did not include consideration of the age of an individual subjected to questioning by police.
"[W]hether the Miranda custody analysis includes consideration of a juvenile suspect's age." More specifically, whether "a child's age 'would have affected how a reasonable person' in the suspect's position 'would perceive his or her freedom to leave.'"
Supreme Court holding:
Yes. "So long as the child's age was known to the officer at the time of police questioning, or would have been objectively apparent to any reasonable officer, its inclusion in the custody analysis is consistent with the objective nature of the test. . . . Just as police officers are competent to account for other objective circumstances that are a matter of degree such as the length of questioning or the number of officers present, so too are they competent to evaluate the effect of relative age."
The Supreme Court reversed the judgment of the North Carolina Supreme Court and remanded the case to the lower court to determine whether, taking his age into consideration, J.D.B. was in custody when he was interrogated.
Four Justices dissented, noting that the Miranda rule "places a high value on clarity and certainty." The dissent states that the majority's holding "shifts the Miranda custody determination from a one-size-fits-all reasonable-person test into an inquiry that must account for at least on individualized characteristic–age–that is thought to correlate with susceptibility to coercive pressures." The dissent asserts that "[t]he Court's decision greatly diminishes the clarity and administrability that have long been recognized as 'principal advantages' of Miranda's prophylactic requirements."
Argued: March 23, 2011
Decided: June 16, 2011
Majority opinion written by Justice Sotomayor and joined by Justices Kennedy, Ginsburg, Breyer, and Kagan
Dissenting opinion written by Justice Alito and joined by Chief Justice Roberts and Justices Scalia and Thomas