Citation. Yarborough v. Alvarado, 541 U.S. 652, 124 S. Ct. 2140, 158 L. Ed. 2d 938, 72 U.S.L.W. 4415, 17 Fla. L. Weekly Fed. S 327 (U.S. June 1, 2004)
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Brief Fact Summary.
Respondent appealed from a conviction of second-degree murder and attempted robbery when he was Mirandized after confessing, purportedly in violation of his Fifth Amendment Rights.
Synopsis of Rule of Law.
Michael Alvarado, 17, was interviewed without his parents about his involvement in a crime. He was not arrested, not Mirandized. During the interview, respondent confessed involvement. Based on those statements, Alvaredo was convicted of second-degree murder and attempted robbery. The Ninth Circuit Court of Appeals reversed the conviction, finding that because defendant was a juvenile and likely felt intimidated he was “in custody” under the terms of Miranda and should have been read his rights. Appeal was brought to the Supreme Court.
Whether a police officer should consider the age and history of a suspect when determining whether he is “in custody” and therefore entitled to his Miranda warnings under the Fifth Amendment.
Reversed. Whether a defendant is “in custody,” and therefore entitled to his Miranda rights, should be determined by objective criterion and not subjective criteria such as age and criminal history.
Justice Breyer dissents, noting that case law makes it clear that in determining whether a defendant is “in custody” for Miranda purposes, the court should consider freedom of movement. In the present case, the dissent argues, respondent was not given freedom of movement.
Concurrence. Justice O’Connor concurs, only adding that when a suspect is close to the age of majority, the fact that he is a juvenile should not be given such weight.
Under the terms of Miranda, a suspect is “in custody” when their freedom of movement is restricted. When a suspect is “in custody,” they must be read their rights. In this case, the majority holds that an interview is not “in custody,” in terms of Miranda, and that a defendant should not be treated any differently if they are a juvenile because freedom of movement is objective, rather than subjective.