U.S. Supreme Court

Supreme Court Rules a Youth’s Age Is Relevant in Miranda Analysis


A youth’s age is relevant when deciding whether a person being questioned by police is in “custody,” triggering the need for a Miranda warning, the U.S. Supreme Court has ruled in a 5-4 decision.

Justice Sonia Sotomayor wrote the majority opinion (PDF). “It is beyond dispute that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave,” she wrote. “Seeing no reason for police officers or courts to blind themselves to that commonsense reality, we hold that a child’s age properly informs the Miranda custody analysis.”

At issue was whether J.D.B., a 13-year-old special education student, had the right to a Miranda warning when he was pulled from his middle school classroom and questioned by a police officer. The North Carolina Supreme Court had ruled the teen was not in custody when he was questioned, so a Miranda warning was not required.

Sotomayor said age is relevant to the analysis and remanded for a new determination of whether the student was in custody. “To hold, as the state requests, that a child’s age is never relevant to whether a suspect has been taken into custody—and thus to ignore the very real differences between children and adults—would be to deny children the full scope of the procedural safeguards that Miranda guarantees to adults,” she wrote.

Justice Samuel A. Alito Jr. dissented. He was joined by Chief Justice John G. Roberts Jr. and Justices Clarence Thomas and Antonin Scalia. “The court’s decision in this case may seem on first consideration to be modest and sensible, but in truth it is neither,” Alito wrote. “It is fundamentally inconsistent with one of the main justifications for the Miranda rule: the perceived need for a clear rule that can be easily applied in all cases.” Age isn’t the only characteristic that may correlate with a suspect’s pliability to questioning, he said, and warned that the decision, if it isn’t limited, could turn the Miranda analysis into a “highly fact-intensive standard.”

The ABA had filed an amicus brief in the case arguing that children, as compared to adults, have unique vulnerabilities. It is the third time in recent years that the ABA has filed an amicus brief on the unique status of children.

ABA President Stephen N. Zack applauded today’s ruling in a statement. “It’s a matter of fact, not just law, that children are not the same as adults,” Zack said. “It is hard to imagine anyone feeling comfortable with a 13-year-old child being questioned by police without a Miranda warning. Today’s decision by the United States Supreme Court in the case of J.D.B. v. State of North Carolina recognizes a child’s unique vulnerabilities and immaturity when it comes to judgment and understanding. The American Bar Association agrees strongly with the court’s smart, fair decision that a child’s age must be considered when making a Miranda custody determination.”

The case is J.D. B. v. North Carolina.

Prior coverage:

ABAJournal.com: “Supreme Court to Decide Teen’s Right to Miranda Warning During School Questioning”

ABA Journal: “Court Probes Whether Officials Can Pull Kids Out of Class for Questioning”

Updated at 1:20 p.m. to include the ABA president’s statement.

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