J. D. B. v. North Carolina

In updating its position in Alvarado, the Court noted that “Justice O’Connor’s concurring opinion explained that a suspect’s age may indeed ‘be relevant to the ‘custody’ inquiry’ (quoting Alvarado).” In some circumstances, “a reasonable child subjected to police questioning will sometimes feel pressured to submit when a reasonable adult would feel free to go.” Therefore, the Court held that “so long as the child’s age was known to the officer at the time of police questioning, or would have been objectively apparent to a reasonable officer, its inclusion in the custody analysis is consistent with the objective nature of that test.”