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Yarborough v. Alvarado


The 17-year old defendant was involved in a murder. About a month later, at the request of a police officer, the defendant’s parents brought him to a police station. With only the officer and the defendant present, the officer conducted a two-hour interview. At the conclusion of this interview, the defendant made incriminating statements. At no time did the officer offer the defendant his Miranda warnings


Whether the defendant’s youth and inexperience must be evaluated in determining whether a reasonable person in his position would have felt as if he was in custody?


No. The Court stated that its prior “opinions applying the Miranda custody test have not mentioned the suspect’s age, much less mandated its consideration.”


Custody must be determined based on how a reasonable person in the suspect’s situation would perceive the circumstances. In making this determination, the Supreme Court has never held that “a suspect’s age or experience is relevant to the Miranda custody analysis.” These factors (as well as education and intelligence) are useful in viewing whether a suspect engaged in a voluntary act, such as in making a statement to law enforcement officers. However, age and experience are not proper factors in determining custody.


541 U.S. 652, 124 S. Ct. 2140 (2004)

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