Saturday, November 2, 2013

Yarborough v. Alvarado case brief

Yarborough v. Alvarado case brief summary
541 U.S. 652 (2004)

Respondent prison inmate was convicted in state court of murder and attempted robbery but asserted that use of his statements to an officer was improper in the absence of a pre-interrogation advisement of rights. Upon the grant of a writ of certiorari, respondent custodial official appealed the judgment of the United States Court of Appeals for the Ninth Circuit which reversed a denial of habeas corpus relief pursuant to 28 U.S.C.S. § 2254(d)(1).

Shortly reaching the age of majority, the inmate was questioned at a police station, at police request, concerning the murder and the inmate eventually admitted participating in the offenses. The state court found that an advisement of rights was not required since the inmate was not in custody at the time of the questioning, but the lower federal appellate court found that the state court unreasonably applied federal law, within the meaning of § 2254(d)(1), by failing to consider the age and inexperience of the inmate in determining that the interrogation was not custodial.

  • The United States Supreme Court held that, while it was arguable whether the inmate was in custody at the time of the interrogation, the state court's determination that the inmate was not in custody was based on a proper application of Supreme Court precedent. 
  • The general test of custody, for purposes of requiring a pre-interrogation advisement of rights, involved the objective circumstances of the interrogation, and the state court's failure to consider the inmate's subjective individual characteristics, such as his age and inexperience, was not an unreasonable application of clearly established federal law.


The judgment which reversed the denial of the inmate's request for habeas corpus relief was reversed.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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