Yarborough v. Alvarado
| Yarborough v. Alvarado | |
|---|---|
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| Argued March 1, 2004 Decided June 1, 2004 |
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| Full case name | Michael Yarborough, Warden, Petitioner v. Michael Alvarado |
| Citations | 541 U.S. 652 (more)
124 S. Ct. 2140; 158 L. Ed. 2d 938; 2004 U.S. LEXIS 3843; 72 U.S.L.W. 4415; 17 Fla. L. Weekly Fed. S 327
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| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Holding | |
| A state court considered the proper factors and reached a reasonable conclusion that a minor was not in custody for Miranda purposes during his police interview, despite the fact that the state court did not consider age or experience with law enforcement in the custody determination. | |
| Court membership | |
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| Case opinions | |
| Majority | Kennedy, joined by Rehnquist, O'Connor, Scalia, Thomas |
| Concurrence | O'Connor |
| Dissent | Breyer, joined by Stevens, Souter, Ginsburg |
Yarborough v. Alvarado, 541 U.S. 652 (2004), is a United States Supreme Court case in which the Court declined to overturn a state court's conclusion that a minor was not in custody for Miranda purposes during his police interview. Michael Alvarado helped his friend Paul Soto steal a truck in Santa Fe Springs, California. The truck owner was killed by Soto during the robbery and Alvarado was convicted of second-degree murder for his role in the crime. The evidence for Alvarado's conviction was primarily based on statements given by Alvarado during a two-hour police interrogation that occurred when Alvarado's parents brought him to the police station. Alvarado was 17 years old and was not read his Miranda rights before questioning. During Alvarado's murder trial in a state court, motions to suppress the statements given by Alvarado were denied on the ground that Alvarado was not in police custody at the time of the interrogation and thus did not have to be read his Miranda rights. Alvarado appealed his conviction, claiming that the determination that he was not in custody was incorrect because the courts did not take his age into account.
In a split decision, the Supreme Court declined to overturn the state court's conclusion about custody because it was not objectively incorrect. The Court noted that there was no precedent that required the use of age in determining whether someone is in police custody (this would change in 2011 with J.D.B. v. North Carolina, which held that age is relevant to determining if someone is in custody). The case has been cited in subsequent Supreme Court decisions as precedent for providing state courts with latitude in making decisions about general or broad rules.
The respondent Michael Alvarado agreed to help his friend Paul Soto steal a truck in the parking lot of a shopping mall in Santa Fe Springs, California. Soto pulled out a gun and approached the driver of the truck, demanding the keys, while Alvarado hid by the driver's side door. The driver refused and was shot and killed by Soto. Afterwords, Alvarado helped hide the gun. Los Angeles County Sheriff's detective Cheryl Comstock led the investigation of the crime. During the investigation Comstock contacted Alvarado's parents, saying that she wished to speak with Alvarado. Alvarado's parents brought him to the police station to be interviewed. Comstock brought Alvarado into an interview room and questioned him for two hours. Alvarado's parents asked to be present during the interview but were not allowed in by police. Alvarado admitted during questions that he had helped his friend try to steal the truck and that he had helped hide the gun.
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