B: ​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).

Directions:
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 the pages below titled: Classifying Arguments
in the Alvarado Case.
3. Answer the questions at the bottom of this document, 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.
 CLASSIFYING ARGUMENTS IN THE ALVARADO CASE

Directions:
The following is a list of arguments in the Yarborough, Warden v. Alvarado court case. Read
through each argument and decide which side of the argument it supports, if any.

You may find it helpful to refer to to the Slide that discusses Miranda v. Arizona (1966) and
Related Precedent Cases.

● Mark a "Y" if the argument supports Yarborough, Warden's side -- that Alvarado was not
in "custody" when he was being questioned, so he was not entitled to be notified of his
Miranda rights. (Police should not have to change their procedures when they interview
juvenile suspects.)
● Mark an "A" if the argument supports Alvarado's side -- that a reasonable juvenile would
not have felt free to leave and therefore was in custody and should have been advised of
his Miranda rights.
● Mark "Both" if the argument supports both sides.
● Mark "N" if the argument supports neither side.
1. ​. A ​ The Supreme Court has already established the legal principle and precedent that juvenile
suspects are, in general, more susceptible to police coercion than adults, so the police and courts
should take a defendant's juvenile status into account when they evaluate procedures to ensure
that confessions are made "voluntarily, knowingly, and intelligently."

2. ​. Y ​ "This Court has often noted that one of the principle advantages of Miranda is that it
provides police and courts with clear guidance about how custodial questioning must be
conducted for statements to be admissible. This Court should not compromise the clarity and
simplicity of Miranda now and start adding new rules depending on the age of the suspect in
question. This would make it more difficult for police to determine when Miranda warnings are
necessary."

3. ​. Y ​ Miranda warnings are only required when a defendant is in custody. The question is how
restrictive the circumstances of the interview are, rather than on the suspect's perception of them.

4. ​. A ​ "Relevant Supreme Court precedents lead us to conclude that Alvarado's youth and
inexperience with the police are simply too important to be ignored."

5. ​. N ​ "The facts of this case make it clear that [Alvarado] was not in custody at the time of his
interview. He was not handcuffed, arrested, or told he was not free to leave. In fact, he was told
the interview would be brief and when the interview was over, he went home with his parents.
Alvarado also testified at trial that the interview was a friendly conversation and was not
confrontational or threatening."

6. ​. A ​ If a juvenile is more susceptible to police coercion during custodial interrogation, then the
same juvenile is more susceptible to the impression that he is, in fact, in custody in the first
place.

7. ​. Y ​ "For the [Ninth Circuit] Court to consider age was beyond the clear weight of Supreme
Court precedent, therefore ... Alvarado's conviction on the basis of his testimony [should be]
reinstated."

8. ​. A ​ What reasonable person, brought to a police station by his parents at police request, put in
a small interrogation room, questioned for two solid hours, and confronted with claims that there
is strong evidence that he participated in a serious crime, could have thought to himself, "Well,
anytime I want to leave I can just get up and walk out?"

3. Discuss the following questions with your group and write down your answers.

● What would we decide in this case if we were Supreme Court justices?

I would rule in Alvarado’s favor. A youth being questioned in relation to any serious
crime without being told that it’s voluntary should be assumed to be in custody. No youth
in their right mind would get up and walk away from a police officer, we’re taught from a
young age that that’s a dangerous thing to do.
● What do we think are the strongest arguments supporting our decision?
He was brought by his parents, held in an interrogation room, questioned for multiple
hours, and was told there was strong evidence he was connected in the crime. No minor
is well-versed enough in the law to know their rights, nor confident enough to get up and
walk away from a police officer.
● What do we think the Supreme Court did decide in this case? Why do we think the Court
decided this way?
I think that the court ruled in Alvarado’s favor, because in my experience police officers
make it clear when you are or aren’t in custody. My freshman year of highschool, I was
questioned by an officer, and he said that I was not in custody and was free to go at any
time, as well as offered to read me my rights if it would make me more comfortable.