Yarborough v. Alvarado
Alvarado was convicted in state court of second-degree murder and attempted robbery. His conviction was obtained primarily based on statements he made during a two-hour interrogation that occurred when he was seventeen years old. Alvarado sought a writ of habeas corpus, alleging that he was deprived of his Fifth Amendment rights in violation of Miranda v. Arizona. The district court denied his petition. The Ninth Circuit Court of Appeals reversed, holding that (1) Alvarado was "in custody" when he was interrogated by police, and thus Miranda warnings were required, and (2) the admission at trial of incriminating statements made by Alvarado during interrogation had a substantial and injurious effect on the jury's verdict.
Questions Presented:
1. Whether, in applying the objective test for a "custody" determination under Miranda v. Arizona, 384 U.S. § 436 (1966), a court must consider the age and experience of a person if he or
she is a juvenile; and
2. Whether a state court adjudication can be deemed an "objectively unreasonable" application of clearly established Supreme Court precedent, for purposes of 28 U.S.C. § 2254(d), because it
declines to "extend" the rule of a Supreme Court precedent to a new context.
