In the Matter of W.R., 363 N.C. 244 (2009)

Under plain error review, the record was insufficient to conclude that the presence of an SRO, at the request of school administrators conducting the investigation, rendered the questioning of the 14-year-old juvenile by school officials a “custodial interrogation,”where no evidence was presented and no findings were made as to the SRO’s actual participation in the questioning. The court reversed the decision of the Court of Appeals which held that admission of the juvenile’s confession resulting from questioning by school officials and a school resource officer was plain error.