Age in police custody
J. D. B. v. North Carolina
In brief
The Supreme Court overturned North Carolina’s ruling and said a child’s age must count in Miranda custody decisions; the state court still must decide whether J.D.B. was in custody.
- Where it stands
- Decided
Decided 5-4 · June 16, 2011 · Opinion by Justice Sotomayor
- What it’s about
- The Supreme Court decided that courts must consider a child’s age when deciding whether police questioning put the child in custody for purposes of Miranda warnings.
- Who it affects
- Courts deciding whether a juvenile was in custody under Miranda must take the child’s age into account.
Summary: written with AI from the case record.
What it's about
It overturned the North Carolina Supreme Court’s ruling and sent the case back to the state court (remanded) to decide whether 13-year-old J.D.B. was in custody during questioning.
J.D.B. was 13 when police questioned him.
The case came from a North Carolina Supreme Court ruling about whether J.D.B. was in custody under Miranda.
Question presented
Should courts consider the age of a juvenile suspect in deciding whether he or she is in custody for Miranda purposes?
What the Court decided
Holding
A child’s age properly informs Miranda’s custody analysis. Pp. 5– 18. 363 N. C. 664, 686 S. E. 2d 135, reversed and remanded.
- Result
- Reversed
The vote
From the opinions
“The Court’s decision in this case may seem on first consideration to be modest and sensible, but in truth it is neither.”
What's next
The case returns to the North Carolina court, which must decide whether J.D.B. was in custody during the questioning, taking his age into account.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Decision Record
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AI analysis generated: Opinion Summary
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - J.D.B.
Opinion added: Opinion
More questions
- Why did Justice Alito disagree?
- He argued that including age would weaken Miranda’s clear, easy-to-apply rule and was not needed to protect children.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.