What is the current state of the law in the context of determining whether a minor is in custody for purposes of Miranda?

In J.D.B. v. North Carolina (2011) 564 U.S. 261, 131 S.Ct. 2394, [180 L.Ed.2d 310] ( J.D.B. ), the court required consideration of youth outside the sentencing context. It held a juvenile's age must be considered in determining whether he or she was in custody for purposes of Miranda v. Arizona (1966) 384 U.S. 436, 86 S.Ct. 1602, [16 L.Ed.2d 694]. "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. 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." ( J.D.B., at pp. 264-265, 131 S.Ct. 2394.)

In Miller v. Alabama (2012) 567 U.S. 460, 132 S.Ct. 2455, [183 L.Ed.2d 407], the court considered mandatory sentences of life without the possibility of parole for juveniles. It held "mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth

[221 Cal.Rptr.3d 592]