Yarborough v. Alvarado

PETITIONER: Michael Yarborough, Warden
RESPONDENT: Michael Alvarado
LOCATION: Guantanamo Bay, Cuba

DOCKET NO.: 02-1684
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 541 US 652 (2004)
GRANTED: Sep 30, 2003
ARGUED: Mar 01, 2004
DECIDED: Jun 01, 2004

ADVOCATES:
Deborah Jane Chuang - argued the cause for Petitioner
John P. Elwood - argued the cause for Petitioner, on behalf of the United States, as amicus curiae
Tara K. Allen - argued the cause for Respondent

Facts of the case

Police interviewed Michael Alvarado, 17, without his parents at a police station about his involvement in a crime. Police neither arrested nor Mirandized Alvarado. During the interview, Alvarado confessed involvement. Based, in part, on these statements, Alvarado was convicted of second-degree murder and attempted robbery. After failed appeals in the California courts, Alvarado unsuccessfully sought a writ of habeas corpus in federal district court in California. The Ninth Circuit Court of Appeals reversed. Recognizing the "in custody" standard to be whether a reasonable person would feel free to end interrogation, the appeals court held that a juvenile is more likely to feel he is in custody. Because Alvarado was "in custody," the Fifth Amendment required that his rights under Miranda v. Arizona (1966) be read to him.

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?

Media for Yarborough v. Alvarado

Audio Transcription for Oral Argument - March 01, 2004 in Yarborough v. Alvarado

Audio Transcription for Opinion Announcement - June 01, 2004 in Yarborough v. Alvarado

William H. Rehnquist:

The opinion of the Court in No. 02-1684, Yarborough against Alvarado will be announced by Justice Kennedy.

Anthony M. Kennedy:

This case begins with a prosecution and conviction for murder.

The defendant at the time of the incident was about 17-and-a-half years old.

He and an accomplice, another young man by the name of Soto, attempted to take a truck.

Carjacking or truck-jacking was the crime.

They attempted to take it from a driver in the shopping mall, and in the course of the attempted theft, Soto shot and killed the driver.

About a month after the incident, the Los Angeles County Sheriff’s Department detective interviewed Alvarado at the police station.

Alvarado was brought to the police station by his parents.

They remained there, although outside the interview room.

The interview lasted for about two hours.

During the interview, Alvarado confessed to his participation in the crime.

He then left the interview with his parents after it was over.

Weeks later, Alvarado was arrested and his statement was used against him at trial.

The problem, as Alvarado sees it, is that he was not given his Miranda warnings during the interview.

The State claims that Miranda warning was not needed because Alvarado was not in custody.

The California Courts agreed with the State.

They found that Alvarado was not in custody so that the statement was properly admitted.

No ran relating was required and the statement was admissible.

The conviction was proper.

The case then went to the federal system where Alvarado sought a writ of habeas corpus.

At this point, the case becomes more complicated that a mere discussion of whether the defendant was in custody.

In habeas cases, Federal Courts are controlled by the provisions of the federal statute, the Antiterrorism and Effective Death Penalty Act known as AEDPA.

Under AEDPA, a Federal Court can set aside a State Court determination only if the State Court’s determination was contrary to or an unreasonable application of clearly established in federal law as determined by the Supreme Court of the United States.

In the habeas proceeding, the United States District Court applied this standard and found that the California determination, that Alvarado was not in custody, was not an unreasonable application of federal law.

But the Court of Appeals for the Ninth Circuit disagreed.

We now hold that the Court of Appeals determination was not consistent with the review standard finding in the Federal Courts.

It can be said that fair-minded jurors could disagree over whether Alvarado was in custody.

And the opinion sets forth arguments that could be made on one side or the other of this issue.

The problem, as we have said, is that Federal Courts on habeas cannot undertake this determination as a de novo matter.

The State Court’s decision fits within the matrix of our prior decisions and does not reflect and unreasonable application of clearly established law.