J.D.B. v. North Carolina

J.D.B. v. North Carolina was a 2011 decision by United States Supreme Court that held that age is relevant when determining police custody for Miranda purposes.

Background
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. The case was appealed and the Supreme Court agreed to hear the case.

After examining the lower court's reasoning, the Supreme Court found that J.D.B.'s age should have been considered when determining whether he was in police custody or not. The Court remanded the case and instructed the lower court to make a new finding on custody while taking age into account.