Yarborough v. Alvarado

In 1995, Michael Alvarado helped his friend Paul Soto try to steal a truck, leading to the death of the truck driver.

17-year-old Alvarado, was taken to the police station by his parents for an interview.  His parents were not allowed into the the interrogation room. Alvarado was neither arrested nor advised of his Miranda rights.

Through-out the 2-hour interview, Alvarado admitted to helping Soto steal the truck and hiding the weapon after the murder. 

When the interview was over, Alvarado was released back to his parents, who drove him home.

Alvarado was then charged with second-degree murder and attempted robbery, based on his confession.

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.

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