Whether a suspect is "in custody" is an objective inquiry. Two discrete inquiries are essential to the determination: first, what were the circumstances surrounding the interrogation; and second, given those circumstances, would a reasonable person have felt he or she was at liberty to terminate the interrogation and leave. The court must apply an objective test to resolve the ultimate inquiry: was there a formal arrest or restraint on freedom of movement of the degree associated with formal arrest.
A uniformed police officer removed the 13-year-old, seventh-grade student from his classroom and escorted him to a closed-door conference room, where he was questioned by police for at least half an hour regarding home break-ins. Prior to the commencement of questioning, the student was not given Miranda warnings. The student confessed. Thereafter, two juvenile petitions were filed against the student, alleging breaking and entering and larceny. The state trial court denied the student's motion to suppress his statements, and adjudicated him delinquent. The North Carolina Supreme Court upheld the decision. In denying the student's motion to suppress, the North Carolina Supreme Court declined to find the student’s age relevant to the determination whether he was in police custody.
Does a child’s age properly inform a Miranda custody analysis?
The Court held that a child's age properly informs Miranda's custody analysis since a reasonable child subjected to police questioning will sometimes feel pressured to submit when a reasonable adult would feel free to go, and courts can account for that reality without doing any damage to the objective nature of the custody analysis. Furthermore, the Court posited that a child's age differed from other personal characteristics that, even when known to police, have no objectively discernible relationship to a reasonable person's understanding of his freedom of action.