Supreme Court Expands Juvenile’s Miranda Rights
On June 16, 2011 the U.S. Supreme Court expanded the Miranda rights of juveniles in the case of J.B.D. v. North Carolina. In a 5-4 decision, the majority held that Miranda warnings may be required during the interrogation of juveniles even if they are not technically in the custody of law enforcement. The “custody” requirement was a benchmark of the Miranda decision; that custodial interrogations were inherently coercive and therefore a suspect needed a warning from law enforcement that stated he or she “had the right to remain silent.” This case puts into law what appears to be common sense; the idea that children are more susceptible to police pressure than adults. Therefore, although not formally in the custody of the police, the interrogation of a child may be as coercive, if not more so, than that of an adult and a Miranda warning is necessary.
In J.B.D. v. North Carolina, a 13-year-old middle school student was suspected of being involved in a pair of home break-ins. A uniformed officer took the student out of class to a conference room, where two officers and two school administrators questioned him for 30 to 45 minutes. The juvenile eventually confessed to the crimes and was subsequently convicted of the crimes.
The Supreme Court reversed the convictions on the grounds that the confession was inadmissible. Writing for the majority, Justice Sotomayor wrote that a child is more likely to feel pressed by the demands of adult authority figures, especially police officers.
This decision appears to be a commonsense extension of the Miranda decision. Of course children are more likely to feel coerced in certain circumstances than adults. Children are still protected by the same Fifth Amendment privilege against self-incrimination as adults and it is good that the Supreme Court recognizes this fact.
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