In the Matter of A.N.C., Jr., 225 N.C. App. 315 (2013)

An officer had reasonable suspicion that criminal activity was afoot to justify an investigatory seizure that occurred when the officer was investigating an alleged larceny of missing cash and observed the juvenile trying to swallow something green. The officer asked A juvenile’s incriminating statement to an officer at the scene of an automobile accident was not involuntary due to the fact that he was required by G.S. 20-166(c) to remain at the scene and provide his name and other identifying information “to the nearest peace officer.” The court rejected the juvenile’s argument that his statement was involuntary, citing California v. Byers, 402 U.S. 424 (1971) (a hit and run statute requiring the driver of a motor vehicle involved in an accident to stop at the scene and give his name and address did not violate the Fifth Amendment). Further, there was no indication of coercive conduct by the officer.