Nearly five years ago, the U.S. Supreme Court decided J.D.B. v. North Carolina, a case arising from the police interrogation of a middle school student in Chapel Hill. In a 5-4 decision, the Court ruled that police officers must consider a juvenile’s age when determining whether they must read juveniles their Miranda rights before questioning them. The ruling represents a major shift in Miranda jurisprudence by establishing a different standard for evaluating police interrogations of juveniles – the reasonable child standard. In the years since J.D.B., however, lower courts have not clearly defined how the reasonable child standard impacts the assessment of whether a juvenile was “in custody.” The application of this new standard also raises questions about how North Carolina courts evaluate custody determinations in the school setting. These and other issues are addressed in “Applying the Reasonable Child Standard to Juvenile Interrogations After J.D.B. v. North Carolina” (No. 2016/01), a new Juvenile Law Bulletin.
J.D.B.
J.D.B., the Supreme Court, and Miranda
As I noted last week, the Supreme Court of the United States just decided J.D.B. v. North Carolina, an important Miranda case. I blogged about the case here when it was decided by the state supreme court, and it’s worth taking another look at it now. I previously summarized the facts as follows: Chapel Hill … Read more
United States Supreme Court to Review In re J.D.B.
I blogged here about In re J.D.B., a juvenile case in which the North Carolina Supreme Court held that a 13-year-old, questioned in an unlocked school conference room by police officers and an assistant principal about the student’s role in several residential break-ins, was not in custody for Miranda purposes. The court stated that “[f]or … Read more
Personal Characteristics and “Custody” for Miranda Purposes
The North Carolina Supreme Court recently decided In re J.D.B., a close and interesting juvenile case. I mentioned it briefly here when it divided the court of appeals. It has implications well beyond the juvenile context, which I’ll unpack at the end of this post. The basic facts are as follows: Chapel Hill police suspected … Read more