In a criminal defense appeals case heard by the United States Supreme Court, the juvenile was a 13 year old special education student in 2005 when the police showed up at his school to question him about a string of neighborhood burglaries. The police had learned that the boy was in possession of a camera that had been reported stolen. The boy was escorted to a school conference room, where he was interrogated in the presence of school officials. The juvenile’s parents were not contacted, and he was not given any Miranda warnings.
The juvenile confessed to the crimes, but later sought to have his confession suppressed on the basis that he was never read his Miranda rights. he argued that because he was effectively in police custody when he incriminated himself, he was entitled to Miranda protections. The North Carolina Supreme Court held that it could not consider the boy’s age or special education status in determining whether he was in custody, and because he was not in custody, he was not entitled to Miranda warnings.
The U.S. Supreme Court held that courts should consider the age of a juvenile in deciding whether or not he or she is in custody for Miranda purposes. Miranda protection only extends to interrogations that are made when a suspect is in custody. If someone is not in custody, but are interrogated then no Miranda protection is required. Similarly, if someone is in custody but is not interrogated, then Miranda warnings are not necessary. If Miranda warnings are violated, then any evidence obtained as a result of that violation in a criminal defense case should not be admissible since it should be found to be the fruit of a poisonous tree.