J. D. B. v. North Carolina

Summary

The Supreme Court held that a child's age properly informs the Miranda custody analysis whenever the child's age was known to the interrogating officer at the time of questioning or would have been objectively apparent to any reasonable officer, because childhood yields objective, commonsense conclusions about how a reasonable person in the suspect's position would perceive his freedom to leave. Applying that rule, the Court reversed the North Carolina Supreme Court, which had refused to consider the 13-year-old petitioner's age and had sustained the denial of his suppression motion after a schoolhouse interrogation conducted without Miranda warnings, and it remanded for the state courts to redetermine custody under the corrected analysis. Justice Alito, joined by The Chief Justice and Justice Scalia and Justice Thomas, dissented, contending that importing age into the custody test abandons Miranda's clear one-size-fits-all reasonable-person standard and is unnecessary given existing voluntariness safeguards.