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APPLYING MIRANDA TO YARBOROUGH, WARDEN V. ALVARADO (2004)
You have been assigned to Group B. You will be studying the case of Yarborough, Warden v. Alvarado (2004).
1. Review the facts of the case and make sure everyone in your group understands them.
2. Classify the arguments made in this case, using a separate handout, Handout #5B: Classifying Arguments in the Alvarado Case.
3. Answer the questions at the bottom of this handout, which ask for your opinions about the case and how you think the Supreme Court decided this case.
Facts of the Case:
Michael Alvarado was a 17-year-old high school student with no prior arrest record. Police were investigating a murder and robbery. A 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. A single detective questioned Alvarado, who was alone, for about two hours.
He was not placed under arrest and was told that he could leave after the questioning ended. His parents drove him home. At no time was Alvarado advised that he had the right to remain silent, the right to consult an attorney prior to questioning, or the right to leave the police station at any time. The detective did ask him twice if he needed to take a break.
The trial judge denied Alvarado's request to exclude the evidence from the interview, which Alvarado claimed should be excluded because he did not receive his Miranda warnings.
Alvarado, who did not pull the trigger of the gun that killed the victim, was convicted of second-degree murder and robbery in large part because of incriminating statements he made during a two-hour interview with a police detective.
How the Case Traveled Through the Courts:
After his conviction, Alvarado appealed his case based on his argument that he was deprived of his Miranda rights under the Fifth and Sixth amendments. The District Court of Appeals denied his appeal, saying a Miranda warning was not required because he was never in custody -- it was not a custodial interrogation and a "reasonable person" would have felt free to leave the interview.
However, the Ninth Circuit Court of Appeals reversed the District Court ruling, saying that the lower court failed to take into account that Alvarado was a juvenile. A juvenile (brought to the station by his parents, questioned for nearly two hours, and presented with strong evidence about his guilt) could reasonably conclude he was not free to leave. The court said 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 that adults and that this difference should apply when judges consider what is a custodial interrogation.
The case was appealed to the Supreme Court of the United States. The Court had to decide if Alvarado was "in custody" at the time of the interview, and therefore should have been given his Miranda warnings. Also, the justices had to decide whether, for Miranda purposes, custody rules applied the same way to adults and juveniles.
1. Be sure that all members of your group understand the facts of the case. Discuss the facts, if necessary.
2. Complete Handout #5B: Classifying Arguments in the Alvarado Case to help you learn about the key arguments on both sides of the case.
3. Discuss the following questions with your group and write down your answers.