Yarborough v. Alvarado
Encyclopedia
Yarborough v. Alvarado, No. 02-1684
(2004), was a case in which the Supreme Court of the United States
held that 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. The respondent Alvarado, a minor at the time, was brought into a police station by his parents and questioned alone in a room by police for two hours. He was convicted of second-degree murder primarily due to statements given to the police officer. Alvarado was not read his Miranda rights before questioning, but attempts to suppress statements given by Alvarado were denied by the state court on the ground that Alvarado was not in police custody while he was being questioned. The Supreme Court held that the state court's determination that Alvarado was not in custody was reasonable.
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. Alvarado was not given a Miranda warning
at any time during questioning.
declined discretionary review.
. Under the Antiterrorism and Effective Death Penalty Act of 1996
, a federal court can grant habeas corpus
to a person held due to a state court judgment if the state-court judgement "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States". The United States District Court for the Central District of California
agreed that the state court rulings were correct, however the Court of Appeals for the Ninth Circuit reversed. The Court of Appeals held that the state court made a mistake in not accounting for Alvarado's youth and inexperience when evaluating custody.
Associate Justice
Anthony Kennedy
wrote the majority opinion for the Court, which held that the state court's custody analysis was reasonable. Kennedy noted that there were facts for and against the claim that Alvarado was in custody. Facts pointing towards custody included that the interview took place at a police station, the interview lasted for two hours, Alvarado was not told he was free to leave, and Alvarado's parents were not allowed to be present during the interview. Facts weighing against custody included that Alvarado was not transported to the police station by police, Alvarado was not threatened or told he would be placed under arrest, and the interview focused on the crimes of Alvarado's friend, not Alvarado's crimes. The Court was not tasked with conducting a separate inquiry into the issue of custody, rather, the Court was tasked with granting relief only if the lower court's decision is objectively unreasonable. Kennedy wrote that, given this standard, the state-court's decision was reasonable because it was not clearly unreasonable.
Central to the reversal of the Ninth Circuit was the fact that the state court did not take into account Alvarado's age and experience with law enforcement in the custody analysis. The Court made several findings on this issue. The Court held that the use of age in custody analysis had not been explicitly required by previous rulings. Inexperience with law enforcement was rejected as well; the Court noted that previous opinions had rejected reliance on such factors.
Sandra Day O'Connor
wrote a concurrence that agreed with the finding that the state court's decision was reasonable. However, O'Connor held that there could be cases in which age would be relevant to custody analysis. This would be affirmed by the Court in 2011 in J.D.B. v. North Carolina
.
Associate Justice
Stephen Breyer
wrote a dissenting opinion, with whom Justice Stevens, Justice Souter, and Justice Ginsburg joined. Breyer disagreed with the majority's holding that fair-minded jurists could disagree on whether Alvarado was in custody, holding that the facts compelled the single conclusion that Alvarado was in custody. Breyer held that the actions the police did not do, such as arrest Alvarado or threaten him, were not as important as what the police did do. Specifically, the police had Alvarado's parents bring him to the police station, brought Alvarado to an interrogation room, kept his parents out, and questioned him for two hours.
In the matter of Alvarado's age, Breyer found that it was relevant to the custody analysis. Further, Breyer held that nothing in the law prevents a judge from including age in the custody analysis. Breyer called the discussion of experience with law enforcement a red herring in the context of the case where Alvarado's age was a known objective fact.
, wrote: "the Court's decision... treated juveniles as the functional equals of adults during interrogation. Over the past quarter-century, developmental psychological research consistently has emphasized adolescents' inability to understand or exercise Miranda rights". Paul Holland, professor at Seattle University School of Law, wrote that "the assumptions Justice Kennedy made in Alvarado are inapplicable to the schoolhouse context... considering the age of a student-suspect questioned at school, would not present a significant risk of compromising the clarity the Court has sought to provide law enforcement. Officers questioning students at school are well aware of the students' status as minors".
, ruling that a child's age is relevant to custody analysis.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2004), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that 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. The respondent Alvarado, a minor at the time, was brought into a police station by his parents and questioned alone in a room by police for two hours. He was convicted of second-degree murder primarily due to statements given to the police officer. Alvarado was not read his Miranda rights before questioning, but attempts to suppress statements given by Alvarado were denied by the state court on the ground that Alvarado was not in police custody while he was being questioned. The Supreme Court held that the state court's determination that Alvarado was not in custody was reasonable.
Crime and investigation
California
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
. 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. Alvarado was not given a Miranda warning
Miranda warning
The Miranda warning is a warning given by police in the United States to criminal suspects in police custody before they are interrogated to preserve the admissibility of their statements against them in criminal proceedings. In Miranda v...
at any time during questioning.
Trial and conviction
The State of California charged Alvarado and his friend with first-degree murder and attempted robbery. Alvarado attempted to suppress his statements given during the Comstock interview on the basis that he was not read his Miranda rights. The trial court denied the motion on the basis that Alvarado was not in police custody at the time he gave his statement. Alvarado was subsequently convicted. Alvarado's conviction was reduced by the trial judge to second-degree murder for his comparatively minor role in the offense. The California Courts of Appeal affirmed the conviction and agreed that Alvarado was not in custody. The Supreme Court of CaliforniaSupreme Court of California
The Supreme Court of California is the highest state court in California. It is headquartered in San Francisco and regularly holds sessions in Los Angeles and Sacramento. Its decisions are binding on all other California state courts.-Composition:...
declined discretionary review.
Petition for habeas corpus
After his conviction, Alvarado filed for a writ of habeas corpusHabeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
. Under the Antiterrorism and Effective Death Penalty Act of 1996
Antiterrorism and Effective Death Penalty Act of 1996
The Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-132, 110 Stat. 1214, is an act of Congress signed into law on April 24, 1996...
, a federal court can grant habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
to a person held due to a state court judgment if the state-court judgement "resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States". The United States District Court for the Central District of California
United States District Court for the Central District of California
The United States District Court for the Central District of California serves over 18 million people in southern and central California, making it the largest federal judicial district by population...
agreed that the state court rulings were correct, however the Court of Appeals for the Ninth Circuit reversed. The Court of Appeals held that the state court made a mistake in not accounting for Alvarado's youth and inexperience when evaluating custody.
Opinion of the court
Associate Justice
Associate Justice or Associate Judge is the title for a member of a judicial panel who is not the Chief Justice in some jurisdictions. The title "Associate Justice" is used for members of the United States Supreme Court and some state supreme courts, and for some other courts in Commonwealth...
Anthony Kennedy
Anthony Kennedy
Anthony McLeod Kennedy is an Associate Justice of the United States Supreme Court, having been appointed by President Ronald Reagan in 1988. Since the retirement of Sandra Day O'Connor, Kennedy has often been the swing vote on many of the Court's politically charged 5–4 decisions...
wrote the majority opinion for the Court, which held that the state court's custody analysis was reasonable. Kennedy noted that there were facts for and against the claim that Alvarado was in custody. Facts pointing towards custody included that the interview took place at a police station, the interview lasted for two hours, Alvarado was not told he was free to leave, and Alvarado's parents were not allowed to be present during the interview. Facts weighing against custody included that Alvarado was not transported to the police station by police, Alvarado was not threatened or told he would be placed under arrest, and the interview focused on the crimes of Alvarado's friend, not Alvarado's crimes. The Court was not tasked with conducting a separate inquiry into the issue of custody, rather, the Court was tasked with granting relief only if the lower court's decision is objectively unreasonable. Kennedy wrote that, given this standard, the state-court's decision was reasonable because it was not clearly unreasonable.
Central to the reversal of the Ninth Circuit was the fact that the state court did not take into account Alvarado's age and experience with law enforcement in the custody analysis. The Court made several findings on this issue. The Court held that the use of age in custody analysis had not been explicitly required by previous rulings. Inexperience with law enforcement was rejected as well; the Court noted that previous opinions had rejected reliance on such factors.
O'Connor's concurrence
Associate JusticeAssociate Justice
Associate Justice or Associate Judge is the title for a member of a judicial panel who is not the Chief Justice in some jurisdictions. The title "Associate Justice" is used for members of the United States Supreme Court and some state supreme courts, and for some other courts in Commonwealth...
Sandra Day O'Connor
Sandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
wrote a concurrence that agreed with the finding that the state court's decision was reasonable. However, O'Connor held that there could be cases in which age would be relevant to custody analysis. This would be affirmed by the Court in 2011 in J.D.B. v. North Carolina
J.D.B. v. North Carolina
J.D.B. v. North Carolina, No. 09-11121 , was a recent case in which the Supreme Court of the United States held that a child’s age properly informs the Miranda custody analysis. The petitioner J.D.B. was a 13 year old student enrolled in special education classes whom police had suspected of...
.
Dissent
Associate Justice
Associate Justice or Associate Judge is the title for a member of a judicial panel who is not the Chief Justice in some jurisdictions. The title "Associate Justice" is used for members of the United States Supreme Court and some state supreme courts, and for some other courts in Commonwealth...
Stephen Breyer
Stephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
wrote a dissenting opinion, with whom Justice Stevens, Justice Souter, and Justice Ginsburg joined. Breyer disagreed with the majority's holding that fair-minded jurists could disagree on whether Alvarado was in custody, holding that the facts compelled the single conclusion that Alvarado was in custody. Breyer held that the actions the police did not do, such as arrest Alvarado or threaten him, were not as important as what the police did do. Specifically, the police had Alvarado's parents bring him to the police station, brought Alvarado to an interrogation room, kept his parents out, and questioned him for two hours.
In the matter of Alvarado's age, Breyer found that it was relevant to the custody analysis. Further, Breyer held that nothing in the law prevents a judge from including age in the custody analysis. Breyer called the discussion of experience with law enforcement a red herring in the context of the case where Alvarado's age was a known objective fact.
Subsequent developments
The decision met with some criticism in the legal community. Berry Feld, professor at University of Minnesota Law SchoolUniversity of Minnesota Law School
The University of Minnesota Law School, located in Minneapolis, Minnesota, USA, is a professional school of the University of Minnesota. The school offers a Juris Doctor , Masters of Law for Foreign Lawyers, and joint degrees with J.D./M.B.A., J.D./M.P.A, J.D./M.A., J.D./M.S., J.D./Ph.D.,...
, wrote: "the Court's decision... treated juveniles as the functional equals of adults during interrogation. Over the past quarter-century, developmental psychological research consistently has emphasized adolescents' inability to understand or exercise Miranda rights". Paul Holland, professor at Seattle University School of Law, wrote that "the assumptions Justice Kennedy made in Alvarado are inapplicable to the schoolhouse context... considering the age of a student-suspect questioned at school, would not present a significant risk of compromising the clarity the Court has sought to provide law enforcement. Officers questioning students at school are well aware of the students' status as minors".
J.D.B. v. North Carolina
Though the Court rejected the argument that its previous holdings supported using age in the custody analysis, the Court did not rule against the use of age. In 2011 the Court clarified in J.D.B. v. North CarolinaJ.D.B. v. North Carolina
J.D.B. v. North Carolina, No. 09-11121 , was a recent case in which the Supreme Court of the United States held that a child’s age properly informs the Miranda custody analysis. The petitioner J.D.B. was a 13 year old student enrolled in special education classes whom police had suspected of...
, ruling that a child's age is relevant to custody analysis.