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  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.
  • Smith’s Criminal Case Compendium is no longer available. Effective June 2025, personnel changes and resource limitations have made it impossible for us to maintain the Compendium to the standard of excellence that the School of Government strives to achieve. We appreciate those who have used and supported the Compendium over the years. We will continue to publish and archive summaries of North Carolina appellate cases concerning criminal law on the North Carolina Criminal Law Blog.

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State v. Yancey, 221 N.C. App. 397 (Jun. 19, 2012)

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Arrest, Search, and Investigation > Interrogation and Confession > Miranda > “Custodial”

The juvenile defendant was not in custody for purposes of Miranda. After the defendant had been identified as a possible suspect in several breaking or entering cases, two detectives dressed in plain clothes and driving an unmarked vehicle went to the defendant’s home and asked to speak with him. Because the defendant had friends visiting his home, the detectives asked the defendant to ride in their car with them. The detectives told the defendant he was free to leave at any time, and they did not touch him. The defendant sat in the front seat of the vehicle while it was driven approximately 2 miles from his home. When the vehicle stopped, one of the detectives showed the defendant reports of the break-ins. The detectives told the defendant that if he was cooperative, they would not arrest him that day. The defendant admitted to committing the break-ins. The juvenile was 17 years and 10 months old at the time. Considering the totality of the circumstances—including the defendant’s age—the court concluded that the defendant was not in custody. The court rejected the argument that J.D.B. v. North Carolina, 564 U.S. 261 (June 6, 2011), required a different conclusion.