Supreme Court rules age is a factor in Miranda custody analysis

[JURIST] The US Supreme Court [official website; JURIST news archive] on Thursday ruled [opinion, PDF] 5-4 in JDB v. North Carolina [Cornell LII backgrounder; JURIST report] that a court should consider a juvenile's age when determining whether the individual is in custody for purposes of the Miranda warning as set forth in Miranda v. Arizona [opinion text]. JDB, a middle-school student, was removed from a classroom and questioned by two law enforcement officers about an incident that took place outside the school campus. The juvenile subsequently made incriminating statements, but was not advised of his Fifth Amendment rights pursuant to Miranda. The Supreme Court of North Carolina held [opinion, PDF] that the student was not in custody when he made the statements and therefore not entitled to the protections of Miranda or North Carolina statute 7B-2101(a) [text]. Miranda warnings are recited to protect a suspect from the inherently coercive nature of police questioning and the Miranda custody analysis requires an examination of the objective circumstances surrounding the interrogation to determine whether a reasonable person would have felt free to leave. Justice Sonia Sotomayor, writing for the majority, pointed out that children lack the requisite understanding and reasoning skills to make mature judgments:

In some circumstances, a child's age "would have affected how a reasonable person" in the suspect's position "would perceive his or her freedom to leave." That is, a reasonable child subjected to police questioning will sometimes feel pressured to submit when a reasonable adult would feel free to go. We think it clear that courts can account for that reality without doing any damage to the objective nature of the custody analysis.
She indicated that the law has traditionally operated on this assumption and that the court's ruling "does not mean that a child's age will be a determinative, or even a significant, factor in every case, but it is a reality that courts cannot ignore." The case was reversed and remanded for further consistent proceedings in the North Carolina Supreme Court.

Justice Samuel Alito, writing on behalf of the dissenters, expressed his discontent with the majority's holding, arguing that considering age tarnishes the clear, prophylactic rule established in Miranda. Age, Alito contends, is a subjective circumstance that forces the evaluator to speculate about the suspect's state of mind, therefore, the new rule places a heavy burden on police. Moreover, the dissent suggests that the new rule unduly expands the otherwise rigid Miranda standard and presents a slippery slope which would permit other subjective circumstances, like intelligence and cultural background, to inform the custody analysis.

 

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