Yarborough v. Alvarado

Facts of the Case

Respondent Alvarado, a 17-year-old suspect, who had allegedly participated in a shooting and an attempted robbery, was called in to a California county sheriff’s station for an interview. Respondent’s parents brought him to the station and waited in the station’s lobby during the 2-hour interview, at which the parents were not present. The interview was conducted by a sheriff’s detective, who did not give respondent the warnings required by

Question

When deciding whether a suspect is in custody and therefore entitled to his Miranda warnings, must an officer consider the suspect’s age and previous history with law enforcement?

CONCLUSION

No. In a 5-to-4 decision written by Justice Anthony Kennedy, the Court ruled that the purpose of the Court’s Miranda decision was to provide an objective rule readily understandable by police officers: when interrogating a suspect who is in custody, an officer must first read the suspect his Miranda rights. Determining whether a suspect is actually in custody has always been based on objective criterion like whether he had been brought to the police station by police or had come of his own accord. Requiring officers to consider individual characteristics of a suspect when determining whether he is in custody, such as the suspect’s age or previous history with law enforcement, would make the test a subjective one that would be more difficult for officers to understand and abide by. Justice Kennedy wrote that the Miranda decision states an objective rule designed to give clear guidance to the police, while consideration of a suspect’s individual characteristics – including his age – could be viewed as creating a subjective inquiry.

Case Information

  • Citation: 541 US 652 (2004)
  • Granted: Sep 30, 2003
  • Argued: Mar 1, 2004
  • Decided Jun 1, 2004