Possible Opinions
Yarborough v. Alvarado |
Opinion
A
The Supreme Court established the legal principle that juvenile defendants are, in general, more susceptible to police coercion than adults; as such, due process demands that a defendant's juvenile status be taken into consideration when determining the proper procedural safeguards that attach to a custodial interrogation. During the last half century, the Court has consistently reaffirmed this principle. If a juvenile is more susceptible to police coercion during a custodial interrogation, then the same juvenile is also more susceptible to the impression that he is, in fact, in custody in the first instance.
. But the lower court failed to address how Alvarado's
juvenile status, including the involvement of his parents
at the behest of police, affected the "in custody" determination.
Relevant Supreme Court precedents lead us to conclude
that Alvarado's youth and inexperience with the police
are simply too important to be ignored. Miranda
warnings should have been given before the interrogation
took place. The Court of Appeals was correct in reversing
the trial court's conclusion that Miranda warnings
were not required.
Opinion B
The
Court adopted Miranda to provide an additional degree
of protection for the constitutional rights to counsel
and against self-incrimination. It does this by prohibiting
evidence of any confession given during a custodial interrogation
from being heard at trial unless the defendant was made
aware of his rights in advance. Miranda notices
are only required when the defendant is in custody, and
the goal of the protection is adequately served by an
objective test for custody that focuses only on the restrictive
circumstances of the interview, rather than on the suspect's
perceptions of them.
.This Court has often noted that one of the principal
advantages of Miranda is that it provides police
and courts with clear guidance about how custodial questioning
must be conducted for statements obtained to be admissible.
Because of the considerable advantage afforded by the
clear guidance Miranda provides, this Court has
stated that the "simplicity and clarity of the holding
of Miranda" are not to be compromised "absent
a compelling justification."
The facts of this case make clear that respondent was not in custody at the time of his interview. There is no indication that he was present at the interview involuntarily, and he was not handcuffed, arrested, or told he was not free to leave. [Alvarado] was interviewed by a single officer, and agreed at trial that the encounter was a "friendly conversation" and was not confrontational. Taken as a whole, the objective circumstances indicate that [Alvarado] was not subjected to the functional equivalent of a formal arrest. The Ninth Circuit misapplied the law in considering Alvarado's age as part of the broader custody determination. Such consideration of age was beyond the clear weight of Supreme Court precedent, therefore the Ninth Circuit was wrong to upset the state court's ruling. Alvarado's conviction on the basis of his testimony is reinstated.
|
|
|
