## Facts

- Police suspected J.D.B., a 13-year-old seventh-grade special education student, of involvement in two home break-ins.
- An investigator went to J.D.B.’s middle school after learning a stolen camera had been found there and linked to J.D.B.
- A uniformed school resource officer removed J.D.B. from class and escorted him to a closed conference room.
- Present during questioning were a plainclothes investigating officer, the uniformed school resource officer, the assistant principal, and an administrative intern.
- J.D.B. was questioned for about 30–45 minutes; no Miranda warnings were given at the outset, and he was not told he was free to leave.
- J.D.B. was not offered an opportunity to contact his grandmother (his guardian) or another supportive adult.
- After initial denials and prompting from school officials to “tell the truth,” J.D.B. asked if he would “still be in trouble” if he returned the items and then admitted involvement.
- Only after the confession did the investigator say J.D.B. could refuse to answer questions and was free to leave; J.D.B. then provided more details and wrote a statement.
- J.D.B. left school by bus; juvenile petitions later charged him with breaking and entering and larceny.
- The trial court denied suppression motions, finding no Miranda custody and that the statements were voluntary; state appellate courts affirmed, holding age could not be considered in the custody analysis.

## Issues

1. Whether a child’s age may be considered in determining whether the child was “in custody” for purposes of Miranda warnings.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that a child’s age is relevant to the Miranda custody inquiry when the age was known to officers or would have been objectively apparent to a reasonable officer.
- The Court directed the state court to reapply the custody test with age included and then determine whether the interrogation was custodial.
- The Court did not itself decide whether J.D.B. was in custody under the corrected standard.

## Legal Principles

- Miranda custody remains an objective test: identify the interrogation circumstances, then ask whether a reasonable person in the suspect’s position would feel free to terminate questioning and leave.
- “Objective” does not require ignoring commonly understood facts; when known or apparent, a suspect’s juvenile status is part of the custody assessment.
- The proper inquiry becomes how a reasonable child of the suspect’s age, in the same setting, would perceive freedom to end questioning.
- Consideration of age is limited to situations where age is known or objectively apparent, preserving administrability.
- Prior decisions declining to treat age as dispositive did not bar courts from considering age; the question was left open and resolved here.

## Conclusion

The Court held that a juvenile’s age, when known or obvious to police, must be considered in the objective Miranda custody analysis, and it remanded for state courts to reassess whether the school interrogation was custodial under that standard.


J.D.B. v. North Carolina, 564 U.S. 261 (2011)