Justices Say Age And Inexperience Are Not Factors For Invoking Miranda

Justices Say Age And Inexperience Are Not Factors For Invoking Miranda

The Supreme Court decided a minor’s age and inexperience with law enforcement do not mandate police must read a Miranda warning before an interrogation.

Provided the youth is not in custody and free to leave at any point when either the youth or parent requests, the justices said police could question without reading a warning.

The high court reversed an opinion from the 9th Circuit, which held police must factor in a juvenile’s age and experience with law enforcement.

“The court of appeals was nowhere close to the mark,” the justices said.

“Our Court has not stated that a suspect’s age or experience is relevant to the Miranda custody analysis.”

The circuit decision had overturned a California Supreme Court upholding the officer’s conduct. The circuit panel said the California court erred in that the officer’s conduct was “unreasonable” and violated the Constitution for failing to read Miranda even though the youth was not in custody.

But the Supreme Court said the California decision was appropriate for the circumstances of the interrogation since the youth was free to leave at any time.

“Certain facts weigh against a finding that [Michael] Alvarado was in custody,” the Supreme Court said. “The police did not transport him to the station or require him to appear at a particular time.”

The case involved a police investigation of a homicide and a carjacking in Santa Fe Springs, Calif.

A detective learned Alvarado might have information about the crime and asked Alvarado’s mother to bring the juvenile to the station house.

His parents transported Alvarado to a meeting with Los Angeles County Sheriff’s Detective Cheryl Comstock, who asked permission for an interview.

The detective questioned Alvarado for about two hours, offering him opportunities for breaks. His parents waited at the station house during the interview and took him home afterwards.

During the questioning, Alvarado identified the shooter and gave other information that eventually led to a conviction. Although he was not charged at the station house, police later arrested the youth.

Alvarado’s attorney alleged a Miranda violation invalidated the youth’s statement. The trial court denied the motion, saying the interview was noncustodial.

Alvarado agreed the atmosphere was friendly and that there was a free exchange of information between himself and the detective.

The Supreme Court said Miranda applies to custodial settings, which was not the case with Alvarado.

The justices said the key elements are that the youth came voluntarily to the police station, was told that he was not under arrest, that he could leave at the end of the interview and that the focus of the inquiry was the chief suspect-a person other than Alvarado.

The detective asked only that Alvarado be helpful to police in establishing facts to solve the crime.

Inf.: Yarborough v. Alvarado, 02-1684, Sup. Ct., June 1.

Copyright Washington Crime News Service Jun 4, 2004

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