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LEGAL

RESEARCH

Yarborough v. Alvarado

Facts

The 17-year old defendant was involved in a murder. About a month later, at the request of a police officer, the defendantโ€™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

Issue

Whether the defendantโ€™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?

Held

No. The Court stated that its prior โ€œopinions applying the Miranda custody test have not mentioned the suspectโ€™s age, much less mandated its consideration.โ€

Discussion

Custody must be determined based on how a reasonable person in the suspectโ€™s situation would perceive the circumstances. In making this determination, the Supreme Court has never held that โ€œa suspectโ€™s age or experience is relevant to the Miranda custody analysis.โ€ 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.

Citation

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

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