Interrogation of student by associate principal does not violate Miranda

In J.D. v. Com., the Virginia Court of Appeals in an opinion by Senior Judge Coleman, joined by Judge Frank and Judge McClanahan, found there was no error in the denial of a motion to suppress self-incriminatory statements by a 14 year-old high school student in response to an interrogation by the associate principal on school grounds, in the presence of the school's safety officer and when the student's father, a teacher, was in the same building. The Court held that the principal is not a law enforcement officer and is not required to give his students a Miranda warning.