U.S. Supreme Court 06-16-11
by: Grapkoch • June 15, 2011 • no comments
Read the full article for details about the following new cases:
- Age a Relevant Factor in Miranda's "Custody" Analysis
This morning, the Court recognized that "[i]t is beyond dispute that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave." Therefore, the Court announces, "[s]eeing no reason for police officers or courts to blind themselves to that commonsense reality, we hold that a child's age properly informs the Miranda custody analysis."
Rejecting the government's argument "that a child's age has no place in the [objective] custody analysis," the Court announces that "[a] child's age is far 'more than a chronological fact' .It is a fact that 'generates commonsense conclusions about behavior and perception.'" And, after citing common sense to appropriately marginalize the government's position, the Court adds further insult by noting that "[a]lthough citation to social science and cognitive science authorities is unnecessary to establish these commonsense propositions, the literature confirms what experience bears out."
Furthermore, the Court reasons, because the law, common experience, and social science all "exhibit the settled understanding that the differentiating characteristics of youth are universal, .[s]o long as the child's age was known to the officer at the time of the interview, or would have been objectively apparent to any reasonable officer, including age as part of the custody analysis requires officers neither to consider circumstances 'unknowable' to them, nor to 'anticipate the frailties or idiosyncrasies' of the particular suspect whom they question."
There are dissents that are worth reading, but one final point by the majority is all that I will highlight in this summary. In part of its assault on the majority conclusion, the dissent argues that the Due Process voluntariness test is sufficient to account for the risk that a child's statements will be involuntary. The majority rejects this argument by stating that, "[t]o be sure, that test permits consideration of a child's age, and it erects its own barrier to admission of a defendant's inculpatory statements at trial .But Miranda's procedural safeguards exist precisely because the voluntariness test is an inadequate barrier when custodial interrogation is at stake." Score a point for the continuing validity of Miranda.
Finally (and on a side note), I don't practice much juvenile law, but this opinion appears to be rife with both authority and precedent recognizing the unique role cognitive development/age play in assessing social interactions-particularly in the criminal justice system. In light of that, it actually presents an opinion that probably should prompt most lawyers to do more than just skim it for its holding.
More information on JDB v. North Carolina can be found at the SCOTUSblog case page, available here.
