| J. D. B. v. North Carolina | |
|---|---|
 | |
| Argued March 23, 2011 Decided June 16, 2011 | |
| Full case name | J. D. B. v. North Carolina |
| Docket no. | 09-11121 |
| Citations | 564 U.S. 261 (more) 131 S. Ct. 2394; 180 L. Ed. 2d 310 |
| Argument | Oral argument |
| Case history | |
| Prior | 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); cert. granted, 562 U.S. 1001 (2010). |
| 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 and mental status is relevant when determining police custody for Miranda purposes, overturning its prior ruling from seven years before. 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. J. D. B. appealed.
The North Carolina Supreme Court held that the Supreme Court's ruling in Yarborough v. Alvarado barred them from determining whether or not he was in custody based on his age. The court determined that a reasonable adult would've felt free to leave; consequently, J. D. B. was not in custody. Thus the court affirmed the ruling of the trial court. J. D. B. appealed, and the U.S. Supreme Court granted certiorari.
The U.S. Supreme Court argued that the age and mental status of an individual can take part in the psychological effect that he faces during police interaction. It's nearly exact to the reasoning of the 1970 Kentucky Supreme Court case of Allee v. Commonwealth, which held that the age and mental status of an individual is relevant in determining whether his statements are involuntary. Based on these reasons, the U.S. Supreme Court reversed the North Carolina Supreme Court and remanded for further proceedings. The North Carolina Supreme Court on remand then determined that J. D. B. was in custody, and remanded for further proceedings.