The U.S. Supreme Court ruled on June 16, 2011 in J.D.B. v. North Carolina that investigating officers must take the age of suspects into account when deciding whether it is necessary to read them Miranda warnings. This is a significant victory, as it demonstrates yet again the Court’s recognition that teens are developmentally different from adults.
At issue in the case was the question of whether the 13-year-old youth in question was in a "custodial setting" when he was interviewed by police and school officials. Historically, Miranda warning analysis has not taken the age of the suspect into account.
Writing for the majority, Justice Sotomayor wrote that, "A child's age is far 'more than a chronological fact" and, "It is beyond dispute that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, we hold that a child's age properly informs the Miranda custody analysis." This ruling reinforces recent holdings from the Supreme Court that youth are fundamentally different than adults, and must be treated accordingly (e.g. Roper v. Simmons and Graham v. Florida).