In re A.N.C., 225 N.C. App. 315 (Feb. 5, 2013)

A thirteen-year-old juvenile was not in custody within the meaning of G.S. 7B-2101 or Miranda during a roadside questioning by an officer. Responding to a report of a vehicle accident, the officer saw the wrecked vehicle, which had crashed into a utility pole, and three people walking from the scene. When the officer questioned all three, the juvenile admitted that he had been driving the wrecked vehicle. Noting that under J.D.B. v. North Carolina, 131 S. Ct. 2394, 2406 (2011), a reviewing court must take into account a juvenile’s age if it was known to the officer or would have been objectively apparent to a reasonable officer, the court nevertheless concluded that the juvenile was not in custody.