J.D.B. v North Carolina
| J. D. B. v. North Carolina | |
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| Argued March 23, 2011 Decided June 16, 2011 |
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| Full case name | J. D. B. v. North Carolina |
| Docket nos. | 09-11121 |
| Citations | 564 U.S. 261 (more) |
| Argument | Oral argument |
| Prior history | Conviction affirmed sub nom. In re J. D. B., 196 N.C.App. 234, 674 S.E.2d 795 (2009); Affirmed, 363 N.C. 664, 686 S.E.2d 135 (2009) |
| Holding | |
| A child’s age properly informs the Miranda custody analysis. | |
| Court membership | |
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| Case opinions | |
| Majority | Sotomayor, joined by Kennedy, Ginsburg, Breyer, Kagan |
| Dissent | Alito, joined by Roberts, Scalia, Thomas |
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 is relevant when determining police custody for Miranda purposes. J. D. B. was a 13-year-old student enrolled in special education classes whom police had suspected of committing two robberies. A police investigator visited J. D. B. at school, where he was interrogated by the investigator, a uniformed police officer, and school officials. J. D. B. subsequently confessed to his crimes and was convicted. J. D. B. was not given a Miranda warning during the interrogation, nor an opportunity to contact his legal guardian.
During the trial, attempts to suppress the statements given by J. D. B. because he was not given a Miranda warning were denied on the grounds that J. D. B. was not in police custody. The case was appealed and the Supreme Court agreed to hear the case J. D. B. v. North Carolina.
After examining the lower court's reasoning, the Supreme Court found that J. D. B.'s age should have been considered when determining whether he was in police custody. The Court remanded the case and instructed the lower court to make a new finding on custody while taking age into account.
A Miranda warning is an explanation of a suspect's rights that must be given by law enforcement before interrogation. It stems from the 1966 Miranda v. Arizona case, and is based primarily on the Fifth Amendment right against self-incrimination. If a defendant in custody is not notified of their rights via a Miranda warning, any confession they give may not be admissible in court. If a defendant is not in police custody, however, police are free to question suspects without informing them of their rights, and their statements may still be admissible.
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