J.D.B. v. North Carolina

564 U.S. 261, 131 S. Ct. 2394, 180 L. Ed. 2d 310 (2011)

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J.D.B. v. North Carolina

United States Supreme Court
564 U.S. 261, 131 S. Ct. 2394, 180 L. Ed. 2d 310 (2011)

SC
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Facts

Police suspected J.D.B. (defendant), a 13-year-old seventh grader, of involvement in home break-ins. A uniformed police officer pulled J.D.B. out of his classroom, took him to a conference room, and questioned him for at least 30 minutes without giving him Miranda warnings. The door to the conference room remained closed during the questioning, and J.D.B. was not told that he was free to leave the room. J.D.B. confessed to the break-ins during this questioning. Only after J.D.B. confessed did an officer tell him that he did not have to answer the investigator's questions and that he could leave the conference room. Two juvenile petitions were filed against J.D.B. His public defender moved to suppress his confession and the resulting evidence, arguing that J.D.B. had been interrogated in a custodial setting without proper Miranda warnings. The trial court denied the motion and ultimately adjudicated J.D.B. delinquent. The appellate court affirmed the judgment. The North Carolina Supreme Court also affirmed, specifically finding that J.D.B. was not in custody when he confessed and that J.D.B.’s age was not relevant to the analysis of whether he was in custody. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Sotomayor, J.)

Dissent (Alito, J.)

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