J.D.B v. North Carolina
In the summer of 2010, NJDC signed onto an amicus brief in support of the petition for certiorari in J.D.B. v. North Carolina, a case asking whether the age of a child subjected to police questions is relevant to the custody analysis of Miranda v. Arizona, 384 U. S. 436 (1966). The United States Supreme Court granted cert, and NJDC signed onto a merits brief in December of that year.
On June 16, 2011, the Court issued a favorable opinion, holding that a child’s age properly informs Miranda’s custody analysis. Justice Sotomayor, writing for the majority, stated that “[a] child’s age is far ‘more than a chronological fact.'” Throughout the opinion, the Court repeatedly referenced “common sense,” noting the “[c]ommonsense reality that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave,” and that children are likely to feel pressured by the demands of authority figures.
This opinion was a victory for the entire juvenile justice community in that it not only expands Fifth Amendment protections against self-incrimination for juveniles, but it also builds upon the jurisprudence acknowledging the unique vulnerabilities of children that the Court has recognized in Roper v. Simmons and Graham v. Florida.
Amicus Brief for Certiorari Filed: June 25, 2010 (download .pdf)
Amicus Brief on the Merits Filed: December 23, 2010 (download .pdf)
Amicus Brief Discusses: Adolescent Development; School Interrogation