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09-11121 J.D.B. v. North Carolina

By: WISCONSIN LAW JOURNAL STAFF//June 16, 2011//

09-11121 J.D.B. v. North Carolina

By: WISCONSIN LAW JOURNAL STAFF//June 16, 2011//

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Criminal Procedure
Miranda warnings; age

A child’s age is relevant to whether he is in custody and Miranda warnings are required.

“In some circumstances, a child’s age “would have affected how a reasonable person” in the suspect’s position “would perceive his or her freedom to leave.” Stansbury, 511 U. S., at 325. Courts can account for that reality without doing any damage to the objective nature of the custody analysis. A child’s age is far “more than a chronological fact.” Eddings v. Oklahoma, 455 U. S. 104, 115. It is a fact that “generates commonsense conclusions about behavior and perception,” Alvarado, 541 U. S., at 674, that apply broadly to children as a class. Children “generally are less mature and responsible than adults,” Eddings, 455 U. S., at 115; they “often lack the experience, perspective, and judgment to recognize and avoid choices that could be detrimental to them,” Bellotti v. Baird, 443 U. S. 622, 635; and they “are more vulnerable or susceptible to . . . outside pressures” than adults, Roper v. Simmons, 543 U. S. 551, 569. In the specific context of police interrogation, events that “would leave a man cold and unimpressed can overawe and overwhelm a” teen. Haley v. Ohio, 332 U. S. 596, 599. The law has historically reflected the same assumption that children characteristically lack the capacity to exercise mature judgment and possess only an incomplete ability to understand the world around them. Legal disqualifications on children as a class—e.g., limitations on their ability to marry without parental consent—exhibit the settled understanding that the differentiating characteristics of youth are universal.

686 S.E.2d 135, reversed and remanded.

09-11121 J.D.B. v. North Carolina

Sotomayor, J.; Alito, J., dissenting.

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