The Supreme Court expanded Fifth Amendment protections against self-incrimination for juveniles in a 5-4 vote Thursday.
The ruling was one of four criminal procedure cases decided Thursday, and the only one to split the court along its ideological divide. The others, variously favoring police or defendants, were unanimous or nearly so.
The case marked a rare expansion of the Miranda rule, which the court adopted in 1966 to deter police from coercing suspects into incriminating themselves. Because the Fifth Amendment prohibits coerced confessions, Miranda requires authorities to warn suspects of their right to remain silent, to ensure that any statement is voluntary.
The court ruled in the latest case that police may have to give Miranda warnings to juvenile suspects in some situations where they could question adults without doing so.
Although the Miranda decision did not spell out age-based distinctions, “commonsense reality” is “that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave,” Justice Sonia Sotomayor wrote for the court, joined by Justices Anthony Kennedy, Ruth Bader Ginsburg, Stephen Breyer and Elena Kagan.
The case came from Chapel Hill, N.C., where police suspected a seventh-grader in a pair of home break-ins. A uniformed officer took the 13-year-old student, identified as J.D.B., from his middle-school classroom to a conference room, where two officers and two school administrators questioned him for 30 to 45 minutes, moving quickly from “small talk” to admonishments to “do the right thing” and warnings of possible “juvenile detention before court,” Justice Sotomayor recounted.
J.D.B., who received neither a rights warning nor the chance to call his guardian, confessed, leading to his conviction. North Carolina courts held that J.D.B. never was in custody, and therefore no Miranda warning was necessary.
The Supreme Court concluded otherwise. “A child’s age is far ‘more than a chronological fact,’ ” Justice Sotomayor wrote, citing precedents dating to the 1940s. A child is more likely to feel pressed by the demands of adult authority figures, conclusions that “are self-evident to anyone who was a child once himself, including any police officer or judge,” she wrote.
In dissent, Justice Samuel Alito wrote that the majority “shifts the Miranda custody determination from a one-size-fits-all…test into an inquiry that must account for at least one individualized characteristic—age.” Joined by Chief Justice John Roberts and Justices Antonin Scalia and Clarence Thomas, Justice Alito wrote that the Miranda rule’s principal benefit was its “rigid” standard for deciding when warnings are required.
Justice Kennedy usually joins other conservatives in siding with police over defendants in criminal procedure cases. But he has split with them in juvenile justice cases, repeatedly finding that minors’ immaturity leaves them less culpable than adults for similar crimes—and therefore ineligible for the harshest punishments of death or life imprisonment without chance of parole.
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