J.D.B. v. North Carolina

On June 16, 2011, the U.S. Supreme Court in the landmark case of J.D.B. v. North Carolina, Case # 09-111121, https://www.supremecourt.gov/opinions/10pdf/09-11121.pdf

held police must consider age and school setting when questioning a child and, therefore, whether they are required to give a Miranda warning. This case involved a thirteen year old seventh grade special education student who was removed from his class, and then taken to a closed door meeting with the school Assistant Principal and questioned by police regarding two burglaries. The U.S. Supreme Court determined that children would not reasonably believe they could leave a room when questioned by police in a school setting and, therefore, must be given a Miranda warning. In other words, this type of a setting was deemed overly coercive because children inherently obey authority and are generally under the belief they must remain in the office and answer questions by a school administrator.

Neither the police nor the school administrators first advised the thirteen year old student of (1) his right to remain silent pursuant to the Miranda warning when questioned; (2) that he was free to leave the room; nor (3) was he afforded an opportunity to talk with his grandmother or legal guardian. After questioning for about forty-five minutes, the student admitted to the burglaries. Juvenile petitions were filed against him, and after a hearing the court adjudicated J.D.B. delinquent. The North Carolina Court of Appeals affirmed as did the North Carolina Supreme Court, holding he was not in custody when he confessed to require a Miranda warning. The U.S. Supreme Court granted Certiorari and reversed the judgment of the state Supreme Court. Essentially, children must be given the same Miranda procedural safeguards that are guaranteed to adults.