Synopsis
of Facts
Yarborough v. Alvarado |
Michael
Alvarado was convicted of second-degree murder and robbery
for his alleged role in a 1995 killing. Alvarado, who
was not the triggerman, was convicted in large part because
of incriminating statements he made during a two hour
interview with a police detective. At the time of the
interview, Alvarado was a 17-year-old high school student
with no prior arrest record. The detective had contacted
Alvarado's mother, who agreed to bring him to the police
station for questioning. When Alvarado arrived with his
parents, the detective denied the parents' request to
remain with their son during the interview. While they
waited in the lobby, Alvarado was questioned alone for
two hours. He was not placed under arrest and was allowed
to leave after the questioning ended. At no time was Alvarado
advised that he had a right to remain silent, a right
to consult an attorney prior to answering, or a right
to leave the police station at any time. Alvarado alleges
he was deprived of his Fifth and Sixth Amendment rights
in violation of Miranda v. Arizona.
Following his criminal conviction, Alvarado brought a
petition in federal district court against Yarborough,
the warden of the prison where he was being held. The
district court denied Alvarado's petition. However, the
Ninth Circuit Court of Appeals reversed, holding that
Alvarado was "in custody" when he was interrogated by
police and, therefore, should have been read his Miranda
warnings. The Ninth Circuit insisted that federal criminal
law treated children differently and this principle should
apply to Miranda custody determinations.
|
