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J.D.B. v. North Carolina

United States Supreme Court

564 U.S. 261 (2011)

Relevant factsFree

Police suspected J.D.B. (defendant), a 13-year-old seventh-grader, of involvement in home break-ins. A uniformed officer pulled him from class into a closed conference room and questioned him for over 30 minutes without Miranda warnings, without telling him he was free to leave. He confessed, and only afterward was he told he could leave or refuse to answer. His public defender moved to suppress the confession, arguing he was interrogated in a custodial setting without proper warnings. The trial court denied the motion and adjudicated him delinquent; the North Carolina Supreme Court affirmed, holding his age was irrelevant to the custody analysis. The U.S. Supreme Court granted certiorari.

IssueFree

Whether the age of a child subjected to police questioning is relevant to whether the child is in custody for purposes of Miranda.

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