Supreme Court Rules In Favor of North Carolina Juvenile: Part I

A U.S. Supreme Court decision based on a North Carolina criminal case has far-reaching importance for juveniles questioned throughout the country. The Supreme Court ruled that police officers questioning a juvenile who is in custody must consider the age of youth. Age is relevant, the Court ruled, when deciding whether a Miranda warning is necessary if the youth is in custody.

Juvenile rights advocates, the American Bar Association and other criminal defense advocates applauded the Supreme Court decision. Critics of the decision noted that the individual decision-making required to fulfill the requirements make it difficult to adhere to the ruling.

Justice Sonia Sotomayor wrote the majority opinion in J.D.B. v. State of North Carolina. The vote was 5-4 with the more liberal justices voting in favor of the juvenile law decision.

Basics of the Supreme Court Decision

The case originated in North Carolina. The facts of the case that led to the Supreme Court decision involve a young boy who was 13-years-old and enrolled in special education courses. Police officers pulled the young boy from his middle school class to question him regarding home break-ins.

The boy was questioned by two police officers and two school administrators. The boy, J.D.B., confessed to the break-ins during the interrogation. The boy’s defense attorney contended in trial court that the confession should be barred since it was obtained prior to a reading of his Miranda’s Rights.

The trial and appeals courts ruled against the defense attorney on the issue because the courts said the boy was not “in custody” and therefore, his Miranda Right’s were not necessary.

However, the Supreme Court disagreed, saying that the boy was in custody because he didn’t feel as though he could leave. The court ruled that a child’s age must be considered when deciding whether a youth feels that he can leave to determine whether the child is “in custody,” triggering the need for the reading of the Miranda Rights.

Another post later in the week will discuss the legal analysis in this important criminal defense decision.

Source: ABC News “Supreme Court: Age Must Be Weighed in Interrogations,” Joan Biskupic, 6/18/2011