Term: 2003
Docket: 02-1684
Michael Yarborough, Warden v. Michael Alvarado
- Pro
02-1684 YARBOROUGH v. ALVARADO Ruling below: CA 9, 316 F.3d 841 QUESTIONS PRESENTED 1. This Court has held that the test to determine if a person is "in custody" to require warnings pursuant to Miranda v. Arizona, 384 U.S. 436 (1966), is an objective test (i.e., whether there is a "formal arrest or restraint on freedom of movement" of the degree associated with a formal arrest). Thompson v. Keohane, 516 U.S. 99, 112 (1995) (quoting California v. Beheler, 463 U.S. 1121, 1125 (1983)); Berkemer v. McCarty, 468 U.S. 420,442 (1984). The question presented is: Whether, in applying the objective test for a "custody" determination under Miranda, a court must consider the age and experience of a person if he or she is a juvenile. 2. Under 28 U.S.C. § 2254(d), a federal court may not grant habeas corpus relief to a state prisoner on a claim adjudicated on its merits in State court unless the adjudication "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." In Williams v. Taylor, 529 U.S. 362, 408 (2000), this Court explicitly left open how "extension of legal principle" cases should be treated under § 2254(d)(I). The question presented is: Whether a state court adjudication can be deemed an "objectively unreasonable" application of clearly established Supreme Court precedent, for purposes of § 2254(d), because it declines to "extend" the rule of a Supreme Court precedent to a new context. CERT. GRANTED: 9/30/03
In the case of Michael Yarborough, Warden v. Michael Alvarado (2003), the U.S. Supreme Court considered whether a police officer's failure to give Miranda warnings to a 17-year-old suspect during an informal interview at a police station should be taken into account when determining if that suspect was in custody for purposes of applying Miranda rights. The court held that it should not, with Justice Kennedy writing for the majority and stating that age alone is not sufficient to conclude someone is in custody for Miranda purposes; other factors such as length and nature of questioning must also be considered. In this case, Alvarado had been questioned by officers about his involvement in an attempted robbery and murder but was never given his Miranda warnings because he wasn't formally arrested until two months later.
In the dissenting opinion for Michael Yarborough, Warden v. Michael Alvarado, Justice O'Connor argued that the majority's decision failed to properly apply precedent and misinterpreted federal law. She contended that a reasonable juvenile in Alvarado's position would have felt free to leave during his police interview; thus it was not a custodial situation requiring Miranda warnings. The fact he was not told he could leave or stop answering questions at any time did not make this an interrogation under custody according to her interpretation of previous rulings by the court on similar matters. Furthermore, she disagreed with the majority’s view that age should be considered when determining whether someone is "in custody" for purposes of issuing Miranda warnings because there is no clear guidance from Congress or state legislatures suggesting age should be such a factor.
