At issue was whether police must advise juveniles of their rights when interrogations are conducted at school.
In June, the United States Supreme Court, in an opinion authored by Justice Sotomayor, reversed the North Carolina Supreme Court by rejecting the State’s argument that a child’s age has no place in the custody analysis. The Court held that “the custody analysis would be nonsensical absent some consideration of a suspect’s age.” “Seeing no reason for police officers or courts to blind themselves to that common sense reality,” the Court explained, “It is beyond dispute that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave.”
The case involved a 13-year-old seventh grade middle school student who was removed from his classroom by four adults, including a uniformed police officer and school resource officer, and questioned in a closed school conference room about alleged delinquent activity off school grounds. The student was not given his Miranda warnings during the interrogation, or prior to his making any statements about his conduct. The student’s attorneys moved to suppress his statements, arguing that he had been interrogated by police in a custodial setting without being afforded Miranda warnings. The North Carolina Supreme Court “declined to extend the test for custody to include consideration of the age … of an individual subjected to questioning by police.”
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