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

An earlier blog post discussed the basics of an important juvenile law decision. With the critical children’s rights decision in the North Carolina juvenile case J.D.B. v. State of North Carolina, the U.S. Supreme Court recognized that age must be considered by law enforcement when a suspect is being questioned. This post will discuss the key legal conclusions for criminal defense cases following the Court’s opinion.

Majority Relied on Individual Determination and Age Considerations

The ruling in this case is that law enforcement must consider the age of the child, considering all relevant circumstances, when determining whether the child feels as though he or she can leave.

The issue of feeling free to leave is a fundamental question to determine whether a suspect is “in custody” or not. If a child is “in custody,” then the child must be read his or her Miranda Rights.

For the majority decision, the Court noted that a child will not often feel the same as an adult when questioned by authority figures. In many cases, a child will not feel as though he or she can leave the questioning. Furthermore, a child’s understanding of criminal questioning will vary greatly depending on the child’s age and experiences.

The majority noted, “To hold, as the state requests, 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,” Justice Sotomayor wrote.

The dissent, however, by Justices Alito, Scalia, and Thomas, as well as Chief Justice, focused on the difficulty of an individual approach to Miranda rights and the “in custody” definition. Justice Alito, writing for the dissent, noted “There is no denying that, by incorporating age into its analysis, the court is embarking on a new expansion of the established custody standard.”

The juvenile in this case, J.D.B., will have his case reheard by the North Carolina lower court to allow the court to apply the new “in custody” standard to determine whether he should have been read his Miranda Rights before his confession, taking his age as a factor.

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