The U.S. Supreme Court has ruled that when a juvenile is a suspect in a police investigation, law enforcement must take into account the child's age when determining whether he is "in custody" and thus must be given a Miranda warning.
This decision concerns a North Carolina 13-year old (J.D.B.) who was suspected of being involved in break-ins at two homes. A police investigator came to the suspect's school, had him pulled from class, and then questioned him for 30-minutes. The investigator did not give him a Miranda warning, allow him to call his guardian, or tell him that he was free to leave. After initially denying involvement in the crimes, J.D.B. finally confessed after he was told he faced juvenile detention. It was only AFTER this admission of guilt that the investigator said J.D.B. was free to leave if he wished and could refuse to answer questions. J.D.B. nonetheless went on to provide additional information about the crimes, including a written statement. He was subsequently found delinquent of breaking and entering and larceny. This judgement was upheld by the North Carolina Court of Appeals and State Supreme Court.
The U.S. Supreme Court ruled that the state courts were in error in not allowing the defendant's age to be a factor in determining whether police had correctly applied the rules concerning a Miranda warning. The Court said that a juvenile's age must be considered when deciding whether a person understands his/her rights while interacting with law enforcement. It is not appropriate, said the Court, for the standard to be how a reasonable adult would act. According to the Court, it is not unreasonable to think that a 13-year old in a school setting, surrounded by school officials and law enforcement, would not understand that he could refuse to answer questions and demand to be "set free."
This is an important decision because it highlights the power wielded by law enforcement and how it must be tempered with reasonable rules that protect individual's rights. For example, in this case, J.D.B.'s age clearly had an impact on how he interacted with the police officer. In a school setting where he is under the control of adult authority figures (teachers and administrators), how does he demand to be "set free"? Where does he go if the questioning ceases? Would he be allowed to call his guardian? Does he even understand he has the right to not answer questions after he has been told by school officials to tell the truth? The Supreme Court has made a common sense decision by saying that someone's age must be a factor in issues of police custody and Miranda warnings.
It should be noted that the Court did not give specific guidelines regarding how age factors into questioning by police. It only said that is should be a factor for courts to consider. This particular case was sent back down to the North Carolina courts for review in light of the Court's decision.
