The U.S. Supreme Court agreed today to consider whether a juvenile burglary suspect who was interrogated at school by the police should have been given a Miranda warning about his rights.
The justices accepted an appeal on behalf of a North Carolina boy identified as J.D.B., who was 13-year-old special education student in 2005 when the police showed up at his school to question him about a string of neighborhood burglaries. The police had learned that the boy was in possession of a digital camera that had been reported stolen.
The boy was escorted to a school conference room, where he was interrogated by a Chapel Hill, N.C., juvenile crimes investigator in the presence of the school resource officer, an assistant principal, and a school administrative intern. J.D.B.'s parents were not contacted, and he was not given any warnings about his rights under the 1966 high court decision in Miranda v. Arizona, such as the right to remain silent or to have access to a lawyer.
After being confronted with evidence about the camera, and with the assistant principal urging him to “do the right thing because the truth always comes out in the end,” J.D.B. confessed to the burglaries and wrote a statement describing the crimes. The police then obtained a warrant and recovered stolen items at J.D.B.'s home and elsewhere.
Lawyers for the boy sought to suppress his confession in a juvenile-delinquency proceeding charging him with two counts each of breaking and entering and larceny, but they lost in lower courts and before the North Carolina Supreme Court.
The state’s highest court rejected the boy’s claim that he was in custody during the school interrogation and should have been given a Miranda warning. In a 4-3 decision in December 2009, the court said it could not consider the boy’s age or special education status in determining whether he was in custody, and because he was not in custody, he was not entitled to Miranda warnings.
“This court adheres to the view that the custody inquiry states an objective rule designed to give clear guidance to the police, while consideration of a suspect’s
individual characteristics—including his age—could be viewed as creating a subjective inquiry,” the North Carolina high court said in its opinion.
One of the dissenting justices said the police took advantage of the middle school’s “restrictive environment and its psychological effect by choosing to interrogate J.D.B. there.”
“It is troubling that in the instant case a public middle school, which should be an environment where children feel safe and protected, became a place where a law enforcement investigator claimed a tactical advantage over a juvenile,” said the dissent.
The youth filed a pauper’s appeal in J.D.B. v. State of North Carolina (Case No. 09-11121). His public defenders argued that the U.S. Supreme Court has never squarely decided whether a juvenile’s age may be considered by courts in making a Miranda custody determination.
“Ignoring a juvenile’s age in making the custody determination undermines Miranda‘s goal of protecting individuals from police coercion,” the appeal on J.D.B.'s behalf says. “This is especially true when a juvenile is interrogated at school.”
The case granted today is the seond of the term involving law enforcement conduct at schools. In October, the high court granted review in Camreta v. Greene (No. 09-1454), which will consider whether child-abuse investigators violate the Fourth Amendment rights of students by interviewing them at school without a warrant or parental consent about suspected child abuse.
The court will hear arguments in the North Carolina case early next year, with a decision likely by late June.
Separately on Monday, the court declined to hear the appeal of Georgia parents whose 13-year-old son committed suicide while he was in the “seclusion room” of a regional special education facility. The parents, Donald and Tina King, sued the Pioneer Regional Educational Service Agency, alleging that the agency violated their son Jonathan’s civil rights by failing to protect him from taking his own life.
The parents lost in Georgia state courts, and the Supreme Court declined without comment to hear their appeal in King v. Pioneer Regional Educational Service Agency. (No. 10-108).
A version of this news article first appeared in The School Law Blog.