Supreme Court rules against N.C. in juvenile Miranda rights

McClatchy NewspapersJune 16, 2011 

WASHINGTON — The Supreme Court ruled against North Carolina today in the case of a juvenile questioned in a Chapel Hill school conference room without being read his Miranda rights.

In J.D.B. vs. North Carolina, the court concluded that police must consider a suspect’s age in determining whether the questioning is “coercive,” and must therefore require the reading of the Miranda rights. The court ruled against N.C. Attorney General Roy Cooper, who argued the case in March.

The 5-4 decision, written by Justice Sonia Sotomayor, says, “A child’s age is far more than a chronological fact.”

While deciding that police must take a suspect’s age into consideration, the court did not issue a decision about whether or not the child in Chapel Hill actually was in custody. Instead, it remanded the case back to the N.C. courts for this decision – “this time taking account of all the relevant circumstances of the interrogation, including J.D.B.’s age at the time.”

The Supreme Court case stems from a situation in September 2005, in which a 13-year-old boy was pulled out of his class at a Chapel Hill, N.C., middle school, escorted to another room and interrogated behind a closed door by a police detective and three other adults.

The boy confessed to a neighborhood larceny. He never was read his so-called Miranda rights, which include the right to an attorney.

Juvenile advocates said the Supreme Court case, J.D.B. vs. North Carolina, could have sweeping implications for young suspects who are questioned by law enforcement. The question before the court was whether an interrogator should consider a suspect's age before deciding whether to read the Miranda warning.

Right now, police must decide whether a "reasonable person" would consider themselves in custody. If the answer is yes, then law enforcement must tell the suspect they have the right to remain silent, to call an attorney and, if under 18, to have his or her parents notified.

The Supreme Court ruled today that the “reasonable standard” should take into effect a suspect’s age.

“Even where a reasonable standard otherwise applies, the common law has reflected the reality that children are not adults,” Sotomayor wrote.

“In fact,” she wrote later, “in many cases involving juvenile suspects, the custody analysis would be nonsensical absent some consideration of the suspect’s age. This case is a prime example.”

The court's decision would be important, observers said this spring before arguments, because it would affect not only how law enforcement officers do their jobs, but also how juvenile suspects are treated.

But those who advocate for law enforcement agencies said earlier this year that youths already have extra protections in court, and that police officers should not bear an additional burden of trying to figure out a suspect's age.

The issue in the Supreme Court case revolves around the word "custody."

Under federal law, a suspect taken into custody must be read his or her Miranda rights by law enforcement. Certain uses of restraint — handcuffs, a prolonged interrogation, certain surroundings — add up to custody.

If the suspect feels free to leave, the rights need not be read.

In J.D.B. vs. North Carolina, the boy was in a conference room with the door closed, but not locked. He was asked twice whether he was OK answering questions.

J.D.B.'s attorneys tried to have the confession suppressed, but the local court refused. That refusal was upheld by state's appeals and supreme courts.

But J.D.B.'s defense attorneys argued that while an adult might have felt free to walk out, a 13-year-old wouldn't.

The respondent argued that wasn’t the case.

In its brief, the North Carolina Attorney General's Office argued that opening the consideration to age isn't fair to law enforcement officers and would require them to consider a range of other possible considerations, such as cultural background, education, mental infirmities or other potential vulnerabilities.

"Miranda works because it sets a clear, bright-line path for police to follow," wrote North Carolina Attorney General Roy Cooper and his staff.

Sotomayor was joined in her decision by Justices Anthony Kennedy, Ruth Bader Ginsburg, Stephen Breyer and Elena Kagan. Writing in opposition was Justice Samuel Alito, joined by Chief Justice John Roberts and Justices Antonin Scalia and Clarence Thomas.

Alito said the court’s majority was wrong, and that the decision is “inconsistent” with one of the main goals of Miranda law – to offer consistency and a clear rule that can be applied in all cases.

“If Miranda’s rigid, one-size-fits-all standards fail to account for the unique needs of juveniles, the response should be to rigorously apply the constitutional rule against coercion to ensure the rights of minors are protected,” Alito wrote.

“There is no need to run Miranda off the rails.”

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