Supreme Court holds age is factor in Miranda rights, Part 1

On behalf of Anaya-McKedy, P.C. posted in Juvenile Crimes on Tuesday, June 28, 2011.

We often discuss juvenile law on this blog and its many differences from the regular criminal justice system that deals with adults. Ultimately, our country decided to structure its justice system for young people focused more on rehabilitation than punishment, although some people argue that it doesn’t do a very good job of it.

Recently, a very important case involving juvenile law was decided by the United States Supreme Court. The case 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 will discuss the case in two parts.

First, a Miranda warning, named after the 1966 Supreme Court case Miranda v. Arizona, means that before police interrogate someone in police custody they must read the person his or her Constitutional rights to an attorney and not to self incriminate. “You have the right to remain silent,” etc. The person in custody must then waive those rights.

If the Miranda rights are not read to the person in custody, the police cannot use the information gained from the interrogation against the person in the case. Oftentimes, there are disputes over what qualifies as “custody” and there have been many court cases defining that word.

The recent case involving juvenile law called J.D.B. v. State of North Carolina asked whether a 13-year-old special education student questioned by a police officer in his principal’s office should have received a Miranda warning. The North Carolina Supreme Court ruled no because the juvenile was not in custody when he was questioned.

Please check back later this week to find out how the Supreme Court ruled.

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