J. D. B. v. North Carolina

J. D. B. v. North Carolina, 564 U.S. 261 (2011), was a case in which the Supreme Court of the United States held that age and mental status is relevant when determining police custody for Miranda purposes, overturning its prior ruling from seven years before.

The U.S. Supreme Court argued that the age and mental status of an individual can take part in the psychological effect that he faces during police interaction.

It's nearly exact to the reasoning of the 1970 Kentucky Supreme Court case of Allee v. Commonwealth, which held that the age and mental status of an individual is relevant in determining whether his statements are involuntary.

[2] J. D. B. was a 13-year-old student attending Smith Middle School in Chapel Hill, North Carolina when he was taken out of class by a uniformed police officer and questioned.

Prior to the questioning, J. D. B. was neither given Miranda warnings nor an opportunity to speak to his legal guardian, nor was he informed that he was free to leave the room.

The North Carolina Supreme Court affirmed with a divided panel, "declin[ing] to extend the test for custody to include consideration of the age... of an individual subjected to questioning by police".

[3] The Supreme Court granted certiorari to determine whether the Miranda custody analysis includes consideration of a juvenile suspect’s age.

[5]The opinion cited Stansbury v. California, where the Court held that a child's age "would have affected how a reasonable person" in the suspect's position "would perceive his or her freedom to leave".

Yarborough v. Alvarado was also cited, where the Court wrote that a child's age "generates commonsense conclusions about behavior and perception".

Alito argued the decision shifted custody determination from a simple test to an inquiry that must account for individualized characteristics.

[7] The Juvenile Law Center praised the ruling as "a resounding statement"[7] in line with "settled research and basic common sense".

[8] Steven Shapiro, legal director of the ACLU concurred, stating that "we have to ensure that students' rights are protected... and the decision is a step in that direction.

[8] John Charles Thomas, representing the National District Attorneys Association, concluded: "The pressure is basically to err on the side of caution, to give the Miranda warning almost every time.

Justice Sotomayor authored the Court's opinion.
Justice Alito authored the opinion for the dissent.