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J.D.B v. North Carolina revolves around a 13-year-old seventh grader suspected of burglary. He was in class when a police investigator came to the school and notified the administration he wanted to question the juvenile. The school resource office pulled him from class and took him to a closed door room. The investigator and assistant principle questioned the juvenile on the burglary and gained a confession.
The admissibility of the confession became the central issue of the case and three North Carolina courts ruled it was admissible because the juvenile was not in custody and therefore not subject to Miranda warnings. However, the US Supreme Court disagreed and reversed the decision, nullifying the admissibility of the confession. The Supreme Court noted in juvenile cases the age must be considered when obtaining confession and during questioning.
The admissibility of juvenile confessions revolves around the juvenile's age and mental state at the time of the questioning. J.D.B v. North Carolina was cited by the Supreme Court; in their view the juveniles are protected when the words or actions of police would lead a juvenile to believe they were not free to leave. In addition, the police questions or statements must be reasonable and not induce an admission.
In People v. White out of Michigan, a seventeen-year-old armed robbery suspect invoked his right to remain silent after being read Miranda rights. Prior to his release an officer stated he hoped White was sure the gun was in a place where no one else could get hurt. White subsequently made admissions which the state used in his conviction. The Michigan Supreme Court upheld this use of juvenile confession stating the age and his apparent understanding of Miranda lent credibility to the assumption that the juvenile acted as an adult.
Thus, when evaluating juvenile confessions, courts face several questions. Does the juvenile display a mature decision making process? Did the juvenile know or reasonably should have known as a child they were free to go or not respond?
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