The Miranda Custody Requirement and Juveniles

Abstract

Concerns about the interrogation process and the ability of minors to navigate the criminal justice system often intersect. The impact of the age of juveniles can be seen in a variety of judicial decisions, most markedly those dealing with punishment. But judicial concern for juveniles goes well beyond sentencing. The interrogation process raises especially grave fears.

Since the Supreme Court issued its landmark ruling in Miranda v. Arizona disallowing compelled inculpatory statements by criminal suspects and defendants, there has been concern as to whether juveniles fully understand and appreciate their rights as articulated in Miranda and based in the Fifth Amendment to the United States Constitution. This Article examines the way a defendant’s age is factored into a court’s review of how the defendant understood his or her rights during the criminal justice process. This Article specifically reviews this question as it concerns a juvenile defendant’s waiver of rights, behavior during interrogation, requests for counsel and other entitlements, custodial status as mandated by Miranda, and his or her general receipt of the Miranda warning. This Article also examines the holding and application of another Supreme Court decision, J.D.B. v. North Carolina, in which the Court articulated the parameters surrounding when age must be considered in making Miranda custody determinations.

Keywords: Juveniles, Miranda, Custody, Interrogation, Criminal Law, Criminal Procedure