J.D.B. v. North Carolina
SummaryOriginal

Summary

A juvenile's age matters for Miranda warnings. Recognizing juveniles may feel pressured to answer police questions, the Court requires considering age in "custody" analysis, potentially triggering Miranda rights for young suspects.

2011 | Federal Juristiction

J.D.B. v. North Carolina

Keywords interrogation of youth; Miranda; police custody; Fifth Amendment (U.S.) ; Miranda warnings; juvenile interrogation

Abstract

The Supreme Court tackled the issue of Miranda warnings and juveniles in J.D.B. v. North Carolina. J.D.B., a 14-year-old, was questioned by police without receiving Miranda warnings. He later confessed to involvement in a murder. The Court, in a 5-4 decision, ruled that a juvenile's age should be considered when determining whether they are in "custody" during questioning. Justice Sotomayor's majority opinion acknowledged that juveniles, unlike adults, may feel compelled to answer police questions even if they don't want to. The Court held that a child's age is a relevant factor in the "custody" analysis under Miranda, potentially requiring Miranda warnings when a reasonable adult wouldn't feel compelled to speak.

Open Case as PDF

Abstract

The Supreme Court tackled the issue of Miranda warnings and juveniles in J.D.B. v. North Carolina. J.D.B., a 14-year-old, was questioned by police without receiving Miranda warnings. He later confessed to involvement in a murder. The Court, in a 5-4 decision, ruled that a juvenile's age should be considered when determining whether they are in "custody" during questioning. Justice Sotomayor's majority opinion acknowledged that juveniles, unlike adults, may feel compelled to answer police questions even if they don't want to. The Court held that a child's age is a relevant factor in the "custody" analysis under Miranda, potentially requiring Miranda warnings when a reasonable adult wouldn't feel compelled to speak.

In the landmark case of J.D.B. v. North Carolina, the Supreme Court addressed the application of Miranda warnings to juvenile suspects. The case involved a 14-year-old, J.D.B., who was subjected to police questioning without being informed of his Miranda rights. Subsequently, he confessed to his involvement in a murder.

The Court, dividing 5-4, held that a minor's age should be factored into the determination of whether they are "in custody" for Miranda purposes. Justice Sotomayor, writing for the majority, recognized that children, as opposed to adults, might experience an obligation to respond to police inquiries even when they would prefer not to. Therefore, the Court determined that the age of a juvenile is a pertinent consideration in the "custody" analysis under Miranda, potentially necessitating Miranda warnings in situations where a reasonable adult would not feel compelled to speak.

Open Case as PDF

Abstract

The Supreme Court tackled the issue of Miranda warnings and juveniles in J.D.B. v. North Carolina. J.D.B., a 14-year-old, was questioned by police without receiving Miranda warnings. He later confessed to involvement in a murder. The Court, in a 5-4 decision, ruled that a juvenile's age should be considered when determining whether they are in "custody" during questioning. Justice Sotomayor's majority opinion acknowledged that juveniles, unlike adults, may feel compelled to answer police questions even if they don't want to. The Court held that a child's age is a relevant factor in the "custody" analysis under Miranda, potentially requiring Miranda warnings when a reasonable adult wouldn't feel compelled to speak.

The landmark Supreme Court case, J.D.B. v. North Carolina, addressed the intersection of Miranda warnings and juvenile suspects. The case revolved around J.D.B., a 14-year-old questioned by law enforcement without being informed of his Miranda rights. Subsequently, he confessed to participating in a murder.

In a 5-4 ruling, the Court determined that a minor's age should be a factor when assessing whether they are "in custody" during police questioning, which triggers the need for Miranda warnings. Justice Sotomayor, writing for the majority, recognized that, unlike adults, young individuals might feel pressured to answer an officer's questions even when they prefer not to. Therefore, the Court concluded that a child's age is a pertinent consideration in the "custody" analysis under Miranda, potentially necessitating Miranda warnings in situations where a reasonable adult might not feel similarly compelled to speak.

Open Case as PDF

Abstract

The Supreme Court tackled the issue of Miranda warnings and juveniles in J.D.B. v. North Carolina. J.D.B., a 14-year-old, was questioned by police without receiving Miranda warnings. He later confessed to involvement in a murder. The Court, in a 5-4 decision, ruled that a juvenile's age should be considered when determining whether they are in "custody" during questioning. Justice Sotomayor's majority opinion acknowledged that juveniles, unlike adults, may feel compelled to answer police questions even if they don't want to. The Court held that a child's age is a relevant factor in the "custody" analysis under Miranda, potentially requiring Miranda warnings when a reasonable adult wouldn't feel compelled to speak.

This case was about a 14-year-old, J.D.B., who was questioned by the police about a murder without being read his Miranda rights. These include the right to not speak to the police and the right to have a lawyer. He confessed to being involved in a murder. The big question for the Supreme Court was whether J.D.B. was really free to leave during that questioning or if he was basically "in custody" and therefore should have gotten those Miranda warnings.

The Court, by a close vote of 5 to 4, said that a young person's age matters in these situations. Justice Sotomayor, who wrote the main opinion, pointed out that kids might feel pressured to answer police questions even when they really don't want to – they might not feel like they can just walk away, even if an adult in the same situation would. Thus, the Court decided that going forward, judges and police need to consider a kid's age when deciding if they're in custody, which could mean more kids will need to hear their Miranda rights before being questioned.

Open Case as PDF

Abstract

The Supreme Court tackled the issue of Miranda warnings and juveniles in J.D.B. v. North Carolina. J.D.B., a 14-year-old, was questioned by police without receiving Miranda warnings. He later confessed to involvement in a murder. The Court, in a 5-4 decision, ruled that a juvenile's age should be considered when determining whether they are in "custody" during questioning. Justice Sotomayor's majority opinion acknowledged that juveniles, unlike adults, may feel compelled to answer police questions even if they don't want to. The Court held that a child's age is a relevant factor in the "custody" analysis under Miranda, potentially requiring Miranda warnings when a reasonable adult wouldn't feel compelled to speak.

The Supreme Court heard and decided a case about a teenager, J.D.B., who was only 14 years old. The police questioned him about a serious crime, but they didn't tell him about his rights, like the right to remain silent. J.D.B. ended up admitting he was involved in a murder.

In a very close decision (5-4), the Supreme Court said that when police are deciding if a kid is "in custody" (meaning they can't leave), they have to think about how old the kid is. Justice Sotomayor, one of the judges, explained that kids sometimes feel like they have to answer police questions even when they don't want to, which is different from adults. This means that sometimes kids need to hear their rights (for example, "You have the right to remain silent…"), even if adults in the same situation wouldn't.

Open Case as PDF

Footnotes and Citation

Cite

J.D.B. v. North Carolina, 564 U.S. 261 (2011)

Highlights