U.S. Supreme Court · 2011
J.D.B. v. North Carolina
564 U.S. 261 (2011)
Holding
Held that a child's age properly informs the Miranda custody analysis when it was known to the officer or objectively apparent. The Court reasoned that a reasonable child subjected to police questioning will sometimes feel pressured to submit when a reasonable adult would feel free to leave, and that age -- unlike idiosyncratic traits -- yields objective conclusions about children as a class without compromising the objective custody test.
Claims this case relied on
Claims relevant to this case
Adolescents are more susceptible than adults to peer influence and to external pressure or coercion, with susceptibility greatest in mid-adolescence; the mere presence of peers measurably increases adolescents' risk-taking and shifts their decisions toward immediate rewards.
Evidence strength: HighScientific consensus: Established· adolescent social influence / coercionJuveniles, especially those age 15 and younger, frequently do not adequately comprehend or appreciate the Miranda warnings they waive: as a group they understand the words of the warnings, and the function and significance of the rights to silence and counsel, less well than adults -- raising doubt about whether a juvenile's waiver is knowing and intelligent.
Evidence strength: ModerateScientific consensus: Established· adolescent legal competence / Miranda waiverJuveniles are over-represented among proven false confessions, and adolescents are at elevated risk of false confession relative to adults -- a dispositional vulnerability (immaturity of judgment, suggestibility, and compliance with authority) that interacts with situational interrogation pressure. The claim concerns the composition of known and proven cases and comparative risk, not a known absolute rate among all juvenile confessions.
Evidence strength: ModerateScientific consensus: Established· false confessions / interrogation reliability