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iLaw Dictionary
California
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 Custody-Miranda
(
YARBOROUGH V. ALVARADO (02-1684))


Criminal Law Trial Evidence INterrogation-Miranda Custody
YARBOROUGH V. ALVARADO (02-1684)

 

=============================================================
YARBOROUGH V. ALVARADO (02-1684)
Web-accessible at:
http://supct.law.cornell.edu/supct/html/02-1684.ZS.html

Argued March 1, 2004 -- Decided June 1, 2004
Opinion author: Kennedy

=============================================================
Respondent Alvarado helped Paul Soto try to steal a truck,
leading to the death of the truck's owner. Alvarado was called in for
an interview with Los Angeles detective Comstock. Alvarado was
17 years old at the time, and his parents brought him to the station
and waited in the lobby during the interview. Comstock took
Alvarado to a small room where only the two of them were present.
The interview lasted about two hours, and Alvarado was not given a
warning under Miranda v. Arizona, 334 U.S. 436. Although he at
first denied being present at the shooting, Alvarado slowly began to
change his story, finally admitting that he had helped Soto try to
steal the victim's truck and to hide the gun after the murder.
Comstock twice asked Alvarado if he needed a break and, when
the interview was over, returned him to his parents, who drove him
home. After California charged Alvarado with murder and
attempted robbery, the trial court denied his motion to suppress his
interview statements on Miranda grounds. In affirming Alvarado's
conviction, the District Court of Appeal (hereinafter state court)
ruled that a Miranda warning was not required because Alvarado
had not been in custody during the interview under the test
articulated in Thompson v. Keohane, 516 U.S. 99, 112, which
requires a court to consider the circumstances surrounding the
interrogation and then determine whether a reasonable person
would have felt at liberty to leave. The Federal District Court
agreed with the state court on habeas review, but the Ninth Circuit
reversed, holding that the state court erred in failing to account for
Alvarado's youth and inexperience when evaluating whether a
reasonable person in his position would have felt free to leave the
interview. Noting that this Court has considered a suspect's
juvenile status in other criminal law contexts, see, e.g., Haley v.
Ohio, 332 U.S. 596, 599, the Court of Appeals held that the state
court's error warranted habeas relief under the Antiterrorism and
Effective Death Penalty Act of 1996 (AEDPA) because it "resulted
in a decision that ... involved an unreasonable application of ...
clearly established Federal law, as determined by [this] Court," 28
U.S.C. sect. 2254(d)(1).

Held: The state court considered the proper factors and reached a
reasonable conclusion that Alvarado was not in custody for Miranda
purposes during his police interview. Pp. 7-15.
(a) AEDPA requires federal courts to consider whether the state-
court decision involved an unreasonable application of clearly
established law. Clearly established law "refers to the holdings, as
opposed to the dicta, of this Court's decisions as of the time of the
relevant state-court decision." Williams v. Taylor, 529 U.S. 362,
412. The Miranda custody test is an objective test. Two discrete
inquiries are essential: (1) the circumstances surrounding the
interrogation, and (2) given those circumstances, whether a
reasonable person would have felt free to terminate the
interrogation and leave. "Once the ... players' lines and actions are
reconstructed, the court must apply an objective test to resolve the
ultimate inquiry: was there a formal arrest or restraint on freedom of
movement of the degree associated with a formal arrest."
Thompson, 516 U.S., at 112. Pp. 7-9.

(b) The state-court adjudication did not involve an unreasonable
application of clearly established law when it concluded that
Alvarado was not in custody. The meaning of "unreasonable" can
depend in part on the specificity of the relevant legal rule. If a rule
is specific, the range of reasonable judgment may be narrow.
Applications of the rule may be plainly correct or incorrect. Other
rules are more general, and their meaning must emerge in
application over time. The more general the rule, the more leeway
courts have in reaching outcomes in case by case determinations.
Cf. Wright v. West, 505 U.S. 277, 308-309. Fair-minded jurists
could disagree over whether Alvarado was in custody. The custody
test is general, and the state court's application of this Court's law
fits within the matrix of the Court's prior decisions. Certain facts
weigh against a finding that Alvarado was in custody. The police
did not transport him to the station or require him to appear at a
particular time, cf. Oregon v. Mathiason, 429 U.S. 492, 495; they
did not threaten him or suggest he would be placed under arrest,
ibid.; his parents remained in the lobby during the interview,
suggesting that the interview would be brief, see Berkemer v.
McCarty, 468 U.S. 420, 441-442; Comstock appealed to Alvarado's
interest in telling the truth and being helpful to a police officer, cf.
Mathiason, 429 U.S., at 495; Comstock twice asked Alvarado if he
wanted to take a break; and, at the end of the interview, Alvarado
went home, ibid. Other facts point in the opposite direction.
Comstock interviewed Alvarado at the police station; the interview
lasted 4 times longer than the 30-minute interview in Mathiason;
Comstock did not tell Alvarado that he was free to leave; he was
brought to the station by his legal guardians rather than arriving on
his own accord; and his parents allegedly asked to be present at
the interview but were rebuffed. Given these differing indications,
the state court's application of this Court's custody standard was
reasonable. Indeed, a number of the facts echo those in
Mathiason, a per curiam summary reversal in which we found it
clear that the suspect was not in custody. Pp. 9-12.

(c) The state court's failure to consider Alvarado's age and
inexperience does not provide a proper basis for finding that the
state court's decision was an unreasonable application of clearly
established law.
The Court's opinions applying the Miranda
custody test have not mentioned the suspect's age, much less
mandated its consideration. The only indications in those opinions
relevant to a suspect's experience with law enforcement have
rejected reliance on such factors. See, e.g., Berkemer, supra, at
442, n. 35, 430-432. It was therefore improper for the Court of
Appeals to grant relief on the basis of the state court's failure to
consider them. There is an important conceptual difference
between the Miranda test and the line of cases from other contexts
considering age and experience. The Miranda custody inquiry is an
objective test, see Thompson, supra, at 112, that furthers "the
clarity of [Miranda's] rule," Berkemer, 468 U.S., at 430, ensuring
that the police need not "gues[s] as to [the circumstances] at issue
before deciding how they may interrogate the suspect," id., at 431.
This objective inquiry could reasonably be viewed as different from
doctrinal tests that depend on the actual mindset of a particular
suspect, where the Court does consider a suspect's age and
experience. In concluding that such factors should also apply to
the Miranda custody inquiry, the Ninth Circuit ignored the argument
that that inquiry states an objective rule designed to give clear
guidance to the police, while consideration of a suspect's individual
characteristics--including his age--could be viewed as creating a
subjective inquiry, cf. Mathiason, supra, at 495-496. Reliance on
Alvarado's prior history with law enforcement was improper not only
under sect.2254(d)(1)'s deferential standard, but also as a de novo
matter. In most cases, the police will not know a suspect's
interrogation history. See Berkemer, supra, at 430-431. Even if
they do, the relationship between a suspect's experiences and the
likelihood a reasonable person with that experience would feel free
to leave often will be speculative. Officers should not be asked to
consider these contingent psychological factors when deciding
when suspects should be advised of Miranda rights. See
Berkemer, supra, at 431-432. Pp. 12-15. 316 F.3d 841, reversed.


Kennedy, J.,

delivered the opinion of the Court, in which Rehnquist, C. J., and
O'Connor, Scalia, and Thomas, JJ., joined. O'Connor, J., filed a
concurring opinion. Breyer, J., filed a dissenting opinion, in which
Stevens, Souter, and Ginsburg, JJ., joined.
YARBOROUGH v. ALVARADO, No. 02–1684 (U.S.S.C. June 01, 2004)


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CRIMINAL LAW & PROCEDURE, HABEAS CORPUS, JUVENILE LAW

YARBOROUGH v. ALVARADO, No. 02–1684 (U.S.S.C. June 01, 2004)
A state court considered the proper factors and reached a reasonable
conclusion that minor defendant was not in custody for Miranda
purposes during his police interview. The District Court's decision
granting habeas relief under AEDPA is reversed.

To read the full text of this opinion, go to:
http://laws.lp.findlaw.com/us/000/021684.html