Miranda Warning Requirement Strengthened for Juvenile Suspects

The Miranda warnings that a police officer is required to provide to an arrested individual, including the fact that the suspect is entitled to an attorney and has the right to remain silent, are ingrained in American culture through their frequent depictions in movies and television. The reality of the Miranda warnings was strengthened today when the Supreme Court ruled in J.D.B. v. North Carolina that a police officer interrogating a juvenile must take youth’s age into consideration when determining whether to give the individual a “Miranda warning.”

The effect of this ruling will be to expand protection for all juveniles suspected of criminal activity, including those faced with possible criminal charges in Maryland. Unfortunately, as the underlying facts of this case demonstrate, the rights of criminal suspects are often violated during police investigations. An experienced Maryland criminal defense attorney can stand up for the rights a person charged with a crime, and protect the constitutional rights that a defendant is entitled to.

In the J.D.B. v. North Carolina case, a 13-year-old suspected in a string of local burglaries. A police officer came to the boy’s school and took the young man out of the classroom to a closed-door conference room where the boy was questioned for 30 minutes. The police officer did not provide J.D.B. with a Miranda warning. Likewise, he was not given the opportunity to call his grandmother or legal guardian. North Carolina argued that the officer’s questioning of J.D.B. was not an interrogation, and J.D.B. was not under arrest, because he could have left the room at any time.

The Supreme Court overturned J.D.B.’s conviction, based on the fact that he had not been provided the proper Miranda warnings. The Court held that sometimes Miranda warnings are required even when an individual is not technically detained, if that person would not understand that he or she was free to leave. Here, the Court felt that the 13-year-old, sitting in a closed-door conference room at his school in the presence of school officials and a police officer, without the assistance of his guardian, might not have understand what his rights were.

The Court held that J.D.B. was essentially in custody, and that interrogation of an individual in police custody creates “inherently compelling pressures.” Miranda v. Arizona, 384 U. S. 436, 467 (1966). The Court pointed out that these pressures can induce individuals to wrongly confess to crimes they never committed at a “frighteningly high” rate. Specifically, the Court’s ruling required that a police officer must take a person’s age into account when determining whether to read to that person his or her Miranda rights. This decision could lead to a dramatic proliferation of Miranda warnings; “the practical effect of the ruling may be that officers, to be on the safe side legally, would give warnings to any suspect who does not appear to be close to age 18.”

Although the Supreme Court provides law enforcement agencies with guidance as to the constitutional rights of criminal defendants, the reality is that those rights are not always respected. Our Maryland criminal defense attorneys are experienced in protecting the rights of individuals accused of criminal activity.

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