Supreme Court Rules: 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 ruled in a 5-4 decision.
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.
Justice Sonia Sotomayor, who wrote the majority opinion, 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.
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.

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