564 U.S. 261 (2011)
In 2005 a 13-year-old seventh-grade student named J. D. B. attended Smith Middle School in Chapel Hill, North Carolina, where police suspected him of breaking into two homes and stealing a digital music player and other items from one of them.1 After a police investigation, Investigator DiCostanzo went to the school to question J. D. B. once a digital camera matching one of the stolen items was found at the school and seen in his possession, and he informed the school resource officer, the assistant principal, and an administrative intern that he wished to question J. D. B. about the break-ins.2
The uniformed school resource officer removed J. D. B. from his classroom and escorted him to a closed conference room where DiCostanzo, the assistant principal, and the intern were present, but J. D. B.'s grandmother, his legal guardian, was never contacted and J. D. B. received no Miranda warnings or information that he was free to leave the room.3 Questioning lasted 30 to 45 minutes, during which J. D. B. initially denied involvement but after being confronted with the camera and warned about the possibility of juvenile detention he confessed to the break-ins and provided details about the location of the stolen items before being allowed to leave to catch the bus home.4
Two juvenile petitions charged J. D. B. with breaking and entering and larceny, and his public defender moved to suppress the statements on the ground that J. D. B. had been interrogated in a custodial setting without Miranda warnings.5 The trial court denied the motion, J. D. B. was adjudicated delinquent, and the North Carolina Court of Appeals and the North Carolina Supreme Court affirmed, holding that J. D. B.'s age was irrelevant to the custody determination.6 The United States Supreme Court granted certiorari to decide whether the Miranda custody analysis includes consideration of a juvenile suspect's age.7
Whether the age of a child subjected to police questioning is relevant to the custody analysis of Miranda v. Arizona?8
The Miranda custody inquiry is an objective test that asks how a reasonable person in the suspect's shoes would have understood his situation.9 A child's age properly informs that analysis so long as the child's age was known to the officer at the time of questioning or would have been objectively apparent to a reasonable officer, because children are less mature and more vulnerable to coercive pressures than adults.10
Yes. The objective custody test examines the totality of circumstances to determine whether a reasonable person would have felt at liberty to terminate the interrogation and leave, and applying that test here shows that J. D. B.
was a 13-year-old seventh grader whose age was known to the officers because they verified his date of birth from school records before questioning began.11 The interrogation took place in a closed school conference room after a uniformed officer removed him from class, with two school administrators present, without any contact with his legal guardian and without informing him he was free to leave, facts that demonstrate age is relevant because a reasonable 13-year-old would perceive the coercive pressures of custody differently from an adult given children's lesser maturity and greater susceptibility to outside pressures, and the lower courts failed to account for this factor in their analysis.12
Related opinions on this issue
Joined by Chief Justice Roberts, Justice Scalia, And Justice Thomas
Justice Alito dissented on the ground that the Miranda custody analysis is an objective test that does not take into account the personal characteristics of the suspect.15 He maintained that the custody inquiry asks how a reasonable person in the suspect's shoes would have understood his situation and that the Court's holding is inconsistent with the long-established principle that the test does not depend on the personal characteristics of the suspect.16 Justice Alito argued that incorporating age will introduce a new and unpredictable element into the Miranda custody analysis because police officers will now have to consider the age of the suspect in determining whether Miranda warnings are required.17
He concluded that the holding will complicate the administration of Miranda and lead to uncertainty in the law without need because the voluntariness test already protects minors.18