Note, You Have the Right to Remain Thirteen: Considering Age in Juvenile Interrogations in J.D.B. v. North Carolina

The Supreme Court's decision in J.D.B. v. North Carolina recognized that age is an objective factor courts must consider when determining whether a juvenile in police custody requires Miranda warnings. Ettlinger examines this holding and its implications for protecting juveniles during interrogation. The note traces Miranda's custodial interrogation doctrine and its extension to juveniles, arguing that children experience interrogation differently than adults due to developmental psychology and cognitive differences. The author supports the Court's determination that age should factor into Miranda custody analysis, noting that juveniles often feel compelled to speak where adults would remain silent. Ettlinger proposes additional safeguards beyond Miranda protections, including mandating parental or guardian presence when juveniles under sixteen are questioned. The article argues that formal Miranda protections are insufficient to secure fairness for minors, requiring implementation of additional procedural protections to account for juveniles' developmental capacities and vulnerability to police pressure.

Topics: Criminal Procedure · Constitutional Law

Keywords: J.D.B. v. North Carolina · Miranda warnings · juvenile interrogation · custody analysis · Fifth Amendment · police coercion · developmental psychology