Summary of Argument

This case involves two issues of extraordinary importance to the lives of vulnerable youth – first, how the school setting affects custody determinations for purposes of Miranda warnings, and second, to what extent age factors into such determinations. This case calls upon the Court to determine whether J.D.B., a 13-year-old, would feel reasonably free to terminate an interrogation and leave the room when he was pulled out of his middle school classroom by a uniformed police officer and escorted to a school conference room where he was then questioned by a police officer and school officials about an off-grounds incident. If he would not feel free to leave, police would be required to issue Miranda warnings. This Court has recognized that the school atmosphere is inherently coercive, making students more vulnerable to pressures, and ultimately in need of unique constitutional protections. See Lee v. Weisman, 505 U.S. 577, 593 (1992) (finding that school children are uniquely susceptible to the pressures of prayer delivered during school events); Hazelwood Sch. Dist. v. Kuhlmeier, 484 U.S. 260, 266-67 (1988) (employing a distinct First Amendment analysis for speech in the school setting). This case presents an opportunity for the Court to clarify how the distinctive pressures of the school environment factor into Fifth Amendment custody determinations.

Historically, this Court has also recognized that the “status of minors under the law is unique.” Bellotti v. Baird, 443 U.S. 622, 633 (1979). The North Carolina court’s conclusion that age does not matter for Fifth Amendment custody determinations contradicts this Court's precedents, statutes and case law from numerous states, and developmental scholarship regarding adolescent perceptions and decision-making. In Yarborough v. Alvarado, 541 U.S. 652 (2004) this Court considered whether the age of a suspect just shy of his 18th birthday mattered for establishing custody. Because Yarborough required the Court to apply a deferential habeas standard, the Court never reached the merits of Alvarado’s case. Id. at 665. J.D.B. v. North Carolina presents an opportunity for the Court to clarify unsettled law in the first instance and provide necessary guidance to state courts and law enforcement. Petitioners have presented thorough information to this Court on the split among state and federal circuit courts as to whether age should be considered in the custody analysis. Amici write separately here to underscore the importance of the issue to vulnerable youth. Amici therefore respectfully request this Court’s clarification that the school setting, combined with the student’s age, should factor into custody determinations under the Fifth Amendment.

Summary of Argument

The case of J.D.B. v. North Carolina presents two significant legal issues regarding the rights of vulnerable youth:

1. The impact of the school environment on custody determinations for Miranda warnings.

2. The consideration of age in such determinations.

The School Environment and Custody

The Supreme Court has acknowledged the inherently coercive nature of the school atmosphere, which can render students susceptible to pressure ( Lee v. Weisman, 1992; Hazelwood Sch. Dist. v. Kuhlmeier, 1988). This unique environment necessitates the consideration of its impact on Fifth Amendment custody determinations. When a student is questioned by police in a school setting, the question arises as to whether they would feel reasonably free to leave the interrogation.

The Role of Age in Custody Determinations

Historically, the Court has recognized the distinct legal status of minors ( Bellotti v. Baird, 1979). The North Carolina court's disregard for age in custody determinations contradicts established precedent and developmental research on adolescent decision-making. In Yarborough v. Alvarado (2004), the Court considered the age of a suspect nearing adulthood but did not reach the merits of the case due to procedural constraints.

J.D.B. v. North Carolina provides an opportunity for the Court to clarify the role of age in custody determinations. The consideration of age is supported by a divergence of opinion among state and federal courts and is crucial for the protection of vulnerable youth.

Conclusion

The Court is urged to consider the combined impact of the school setting and the student's age in determining custody under the Fifth Amendment. This clarification would provide guidance to law enforcement and courts, ensuring the protection of the rights of vulnerable youth.

Summary of Argument

School Setting and Custody for Miranda Warnings

When a 13-year-old student named J.D.B. was questioned by police in a school conference room, the question arose: should he have received Miranda warnings? Miranda warnings are required when a person is in custody, meaning they do not feel free to leave.

The school setting is considered inherently coercive, meaning students may feel pressured and vulnerable. This is especially true when a uniformed police officer is present. Therefore, it is important to consider the school setting when determining if a student is in custody.

Age and Custody Determinations

Historically, courts have recognized that minors have a unique status under the law. Developmental research shows that adolescents may perceive situations differently and make decisions differently than adults.

In this case, the North Carolina court ruled that age does not matter for custody determinations. However, this contradicts previous court rulings and research on adolescent development.

Conclusion

This case presents an opportunity for the Supreme Court to clarify how the school setting and a student's age should be considered when determining if Miranda warnings are required. This clarification is essential for protecting the rights of vulnerable youth.

Summary of Argument

When Can Police Question You Without Miranda Warnings?

This case is about a 13-year-old named J.D.B. who was questioned by police at his middle school. The question is: should he have been given Miranda warnings?

Miranda warnings are those things you hear on TV: "You have the right to remain silent..." Police have to give these warnings when they're questioning someone who is "in custody," meaning they don't feel free to leave.

The School Setting

Schools are different from other places. Students are often pressured to do what adults tell them, and they may feel like they can't leave even if they want to. That's why courts have said that schools are "inherently coercive," meaning students are more likely to feel pressured.

Age Matters

The court in this case said that age doesn't matter when deciding if someone is in custody. But other courts and experts say that it does. Kids are different from adults. They may not understand their rights or be able to make good decisions when they're under pressure.

What's at Stake

This case is important because it will help decide how police can question kids at school. If the court says that J.D.B. was not in custody, then police will be able to question kids at school without giving them Miranda warnings. But if the court says that he was in custody, then police will have to give kids Miranda warnings before questioning them at school.

Summary of Argument

This is a big case about two important things for kids and teens:

• How being at school affects when police have to read you your rights

• How age matters in these situations

Young People's Rights at School

A 13-year-old named J.D.B. was taken out of class by a police officer and questioned in a school office. He wasn't told that he could leave or stop answering questions.

Schools are different from other places because kids have to be there and follow rules. This can make kids feel like they can't say no to adults, even police officers.

The court in this case said that age doesn't matter when deciding if someone should be told their rights. But other courts and experts say that it does.

Kids are still learning and growing, and they might not understand their rights or be able to stand up for themselves as well as adults.

The people who are helping J.D.B. want the court to say that both being at school and being a kid should be considered when deciding if someone needs to be told their rights.