Yarborough v. Alvarado
541 U.S. 652, 124 S. Ct. 2140, 158 L. Ed.2d 938 (2004)

  • Alvaredo was 17 years old when the police suspected Alvarado and another teen, Soto, of stealing a truck and killing a guy. They called his parents, who brought him to the police station. They separated him from his parents and questioned him for 2 hours. He confessed.
    • At no time did the police tell Alvarado he had the right to remain silent, as required by Miranda v. Arizona (384 U.S. 486 (1966)) (aka a Miranda Warning).
      • The police do not like to give warnings because it decreases the chance that the suspect will talk.
        • Although statistically most people waive their rights anyway.
    • Most of the questioning was directed at getting Alvarado to implicate Soto, not to get Alvarado to implicate himself.
  • After the confession, Alvarado was arrested on suspicion of robbery, and his statements to the police were used against him at trial.
  • The Trial Court convicted Alvarado of robbery. He appealed.
    • Alvarado argued that the confession should be inadmissible because had not been warned.
    • The prosecution argued that Alvarado came to the police station of his own volition, and was not “in custody” at the time he made his statements. He was always free to leave. It was just a friendly chat.
  • The Appellate Court upheld the conviction. Alvarado filed a writ of habeus corpus in Federal court.
  • The Federal Trial Court upheld the conviction. Alvarado appealed.
  • The Federal Appellate Court overturned the conviction. The prosecutor appealed.
    • The Federal Appellate Court found that since Alvarado was young and inexperienced, he was less likely to understand that he was not in custody and was not compelled to answer.
  • The US Supreme Court reversed and upheld the conviction.
    • The US Supreme Court found that there is an objective standard; would a reasonable person feel they were in custody. Alvarado was arguing a subjective standard; would Alvarado have felt he was in custody.
      • The Court noted that the whole purpose of the Miranda decision was to provide the police with a clear rule so they do not need “to make guesses as to the circumstances at issue before deciding how they may interrogate a suspect.”
    • The Court looked objectively at the facts of the case and found that a reasonable person in Alvarado’s situation would have understood that they were not in custody.
      • The Court used a Totality of the Circumstances test.
    • The Court noted that there was a decent argument that Alvarado was in custody, but it was reasonable for the Trial Court to have concluded that he wasn’t, and the Supreme Court should defer to the Trial Court’s conclusion unless it was unreasonable (that’s the standard for a habeus corpus appeal).
  • In a dissent it was argued that common sense would say that it was unreasonable to assume that someone in Alvarado’s position would feel that they could just stand up and walk out of interrogation room and go home.
    • In addition, the dissent felt that an objective standard might not be the right standard, because Alvarado was not a middle-aged person well versed in police tactics, he was just a kid.
  • Btw, a Terry stop is not an arrest, and the suspect is not considered to be in custody, so there is no requirement for Miranda Warning.