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Supreme Court holds age is factor in Miranda rights, Part 2

Welcome back to our discussion on the recent United States Supreme Court case which held that a juvenile's age should be a factor when deciding whether the young person was considered "in custody" for purposes of a Miranda rights analysis. We began the topic in the last post.

J.D.B. v. State of North Carolina involved a 13-year-old special education student who was questioned by a police officer in his principal's office after he was under suspicion of committing a minor crime. The issue was whether or not the juvenile should have received a Miranda warning.

The Supreme Court disagreed with the North Carolina Supreme Court's decision and remanded the case, instructing the lower court to consider the juvenile's age while deciding if the teen was in custody for purposes of a Miranda analysis.

The Supreme Court wrote that "[t]o 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."

The American Bar Association, which submitted a brief on behalf of the 13-year-old, argued that juveniles are more vulnerable than adults and this needs to be taken into consideration. In other words, a younger person might not feel like he or she has the ability to leave when questioned by police, whether if it's in a school office or police station, so a custody analysis should be less rigid for juveniles.

The president of the American Bar Association said he was pleased with the Court's decision. "It's a matter of fact, not just law, that children are not the same as adults," he said in a statement. "It is hard to imagine anyone feeling comfortable with a 13-year-old child being questioned by police without a Miranda warning."

Source: ABA Journal, "Supreme Court Rules a Youth's Age Is Relevant in Miranda Analysis," Debra Cassens Weiss, 6/16/2011.

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