The Supreme Court expanded Miranda protections for juveniles June 16 in a case with potentially significant implications for children with disabilities, whom regularly are disciplined at a disproportionately high rate in schools nationwide.
The case centers on a 13-year-old boy enrolled in special education, whom police suspected of being involved in two home-break-ins. A uniformed police officer removed the boy from class and, in the presence of an assistant principal and an administrative intern, questioned the boy for 30 to 45 minutes in a closed conference room.
After the boy was told he could potentially be placed in a juvenile detention, the boy confessed to being involved in the break-ins. The officer then informed the boy of his Miranda rights to “remain silent.”
Police are regularly not required to inform suspects of their Miranda rights until they are in custody. The Supreme Court ruled that the boy’s obvious youth required that the police inform the boy of his rights prior to questioning him. The question of whether the boy was in custody hinges on whether or not he believed he could have left the conference room. The court noted the effects of the child’s compulsory attendance in school and the fact that disobedience at school was grounds for disciplinary action.
“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,” wrote Justice Sonia Sotomayor for the 5-4 majority, which split along ideological lines. “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.”
Regan Bailey, director of legal advocacy at Disability Rights Washington, said the case is timely amid the recent increase in the number of police officers in schools nationwide, estimated to be about 17,000 officers. These officers regularly respond to “disturbances” at the school, which are often manifestations of the student’s disabilities.
Noting that the Individuals with Disabilities Education Act prohibits schools from suspending students for actions that manifest from their disabilities, Bailey argues the court’s decision pushes back against a legal inconsistency: that a student with disabilities are not similarly protected from police action, even arrest, in the schools.
“The Court’s recognition of the need for protections for children in schools from combined coercive effects of police and school is a welcome step in the right direction,” Bailey said.
The decision reverses the decisions from the North Carolina Supreme Court, which refused to suppress the evidence obtained by the police prior to informing the child of his Miranda rights.
Disability Rights Washington is part of the federally funded protection and advocacy system and a member of the National Disability Rights Network.