In the Matter of K.D.L., 207 N.C. App. 453(2010)

Statements of a 12-year-old juvenile made in response to questioning by the school principal resulted from “custodial interrogation,” where a school resource officer (SRO) frisked the juvenile, transported him to the principal’s office in a patrol car, and was present for most of the lengthy interrogation. Even though the officer asked no questions, a Miranda warning was required because the SRO’s near-constant supervision of the juvenile’s interrogation and “active listening” could cause a reasonable person to believe the principal’s interrogation was done in concert with the SRO or that the person would endure harsher criminal punishment for failing to answer.