J.D.B. v . North Carolina

1. J.D.B. v. North Carolina Leandra Bowsman, Lia and Jenna Smith

2. Summary of Facts and Issue • The issue of the case is whether or not J.D.B. was Mirandized, and whether or not his age was a factor in determining if he thought that he was in custody. • J.D.B., a thirteen year old at the time of the incident, was suspected of stealing household items.  He was caught on tape and seen in school with one of the missing items five days after the incident occurred.  He was questioned by a police officer and neither given the Miranda warnings, allowed him to call his grandmother (legal guardian at the time), nor told him he was allowed to leave.  He was in a closed-off room and questioned for at least 30 minutes. 

3. Summary of Facts and Case continued • He didn't confess until the officer, DiCostanzo urged him to tell the truth and told him he could go to juvenile detention.  Only after the confession was he told that he was free to leave.  He went into more detail about the incidents and wrote a statement.  He was allowed to catch the bus at the end of the school day, but two juvenile petitions were filed against him. They charged him with breaking, entering and stealing.  • His public defender said that he was not Mirandized and had been in a custodial interrogational setting.  He also said that his statements were involuntary.   • The court denied this and entered a transcript of admission to the charges but renewed his objection to the denial of his motion to suppress.  The court declared that he was a delinquent and the North Carolina Court of Appeals and State Supreme Court agreed.  The Supreme Court finally decided that age was relevant to the case, and remanded it.

4. Decision and Reasoning • In this case, the court ultimately decided that J.D.B.’s age should be taken into account when deciding whether or not he was in custody. The case was remanded (in this case, it means that the case was returned to the lower courts to reexamine all relevant circumstances of the interrogation, including age.) • The court’s reasoning was that children have a different way of understanding the world than adults. Children lack the capacity to understand events the same way an adult would, and therefore their age and lack of mature thinking must be taken into account. Police and courts must “examine all of the circumstances surrounding the interrogation, including those that would have affected how a reasonable person… would perceive his or her freedom to leave.” In custody, when people are under pressure, they may admit to crimes that they never committed. The court found that children and teenagers have a higher chance of reacting to this stress than adults would.

5. Whose Side Will This Benefit? • This case and the reasoning behind the decision will benefit the defense (the side of Dakota Allen). This is because the case takes maturity into account, and because Dakota is a juvenile, he/she may react to stress differently than an adult would.