Yarborough v. Alvarado

Yarborough v. Alvarado was a 2004 decision by the United States Supreme Court case in which the Court declined to overturn a state court's conclusion that a minor was not in custody for Miranda purposes during his police interview.

Background
Michael Alvarado helped his friend Paul Soto steal a truck in Santa Fe Springs, California. The truck owner was killed by Soto during the robbery and Alvarado was convicted of second-degree murder for his role in the crime. The evidence for Alvarado's conviction was primarily based on statements given by Alvarado during a two-hour police interrogation that occurred when Alvarado's parents brought him to the police station. Alvarado was 17 years old and was not read his Miranda rights before questioning. During Alvarado's murder trial in a state court, motions to suppress the statements given by Alvarado were denied on the ground that Alvarado was not in police custody at the time of the interrogation and thus did not have to be read his Miranda rights. Alvarado appealed his conviction, claiming that the determination that he was not in custody was incorrect because the courts did not take his age into account.

Results
In a split decision, the Supreme Court declined to overturn the state court's conclusion about custody because it was not objectively incorrect. The Court noted that there was no precedent that required the use of age in determining whether someone is in police custody (this would change in 2011 with J.D.B. v. North Carolina, which held that age is relevant to determining if someone is in custody). The case has been cited in subsequent Supreme Court decisions as precedent for providing state courts with latitude in making decisions about general or broad rules.