D.Z. v. State

D.Z., a public school student, was questioned as part of an investigation jointly undertaken by the school’s assistant principal and a police officer stationed at the school about graffiti found in one of the school’s restrooms. The assistant principal first questioned D.Z. alone in his office, employing classic interrogation techniques until an incriminating statement was obtained. He then turned D.Z. immediately over to the officer, who again interrogated D.Z. and subsequently filed charges against him. D.Z. was not given his Miranda warnings prior to either interrogation or advised that this school discipline issue could result in criminal charges. The Indiana Court of Appeals held that Miranda protections are required before a child’s statements to a school administrator working in concert with police can be used against the child in court. The State appealed to the Indiana Supreme Court.


Juvenile Law Center filed an amicus brief in the Indiana Supreme Court in support of D.Z. Our brief argued that children are entitled to special constitutional protections in the context of interrogations. We also argued that school-based policing practices heighten the need for meaningful due process protections because these interrogations—whether conducted by school officials or police officers—are often intended to lead not just to school discipline, but to juvenile and criminal charges that can have lifelong consequences.

The Indiana Supreme Court affirmed D.Z.’s adjudication, holding that when school officials are not agents of the police, they can question students without providing Miranda warnings. In a companion case, decided the same day, the court held that a student who was questioned in a vice-principal's office with police officers present was entitled to Miranda protections. The court emphasized that “confessions of juveniles require special caution” and “there is no ‘educational purpose’ exception to Miranda.”