## Facts

- Police investigated a robbery-murder involving a truck and questioned Michael Alvarado, age 17, at a police station.
- Alvarado came to the station with his parents, who waited in the lobby while he was interviewed in a separate room.
- A detective questioned Alvarado in a small interview room for about two hours; Alvarado was not given Miranda warnings.
- Alvarado initially denied involvement but later made inculpatory statements, including that he helped another person attempt to steal the truck and later hide the gun used in the killing.
- The detective did not formally arrest or restrain Alvarado during the interview, asked twice whether he needed a break, and permitted him to leave at the end with his parents.
- In state court, Alvarado moved to suppress his statements on the ground that the interview was custodial without Miranda warnings; the trial court denied the motion, and the state appellate court affirmed under an objective “reasonable person” custody standard.
- On federal habeas review, the district court denied relief, but the Ninth Circuit granted relief, reasoning that the state court unreasonably failed to account for Alvarado’s youth and inexperience in the custody analysis.

## Issues

1. Whether, under 28 U.S.C. § 2254(d)(1), the state court unreasonably applied clearly established Supreme Court precedent in concluding Alvarado was not “in custody” for Miranda purposes.
2. Whether clearly established Supreme Court law required consideration of a suspect’s age and inexperience in the Miranda custody determination such that a state court’s failure to do so is objectively unreasonable on federal habeas review.

## Decision

- The Supreme Court reversed the Ninth Circuit in a 5–4 decision.
- The Court held that the state court’s determination that Alvarado was not in custody was not an unreasonable application of clearly established federal law, so habeas relief was unavailable under AEDPA.
- The Court reasoned that the Miranda custody test is an objective standard designed to guide police and that existing Supreme Court holdings did not clearly require incorporating age or prior experience as mandatory custody factors.
- Given the mixed facts, the state court’s no-custody conclusion fell within the range of reasonable applications of the general Miranda custody framework.
- A concurrence agreed with the judgment and indicated age may sometimes matter, but concluded AEDPA deference foreclosed relief on these facts.
- A dissent would have found custody and viewed youth as relevant to how a reasonable person would experience the interrogation, and would have granted relief even under AEDPA.

## Legal Principles

- Miranda warnings are required only when a suspect is subjected to custodial interrogation; custody turns on whether, under the circumstances, a reasonable person would have felt free to terminate the interview and leave.
- Under AEDPA, federal habeas relief is limited to state-court decisions that are contrary to, or involve an unreasonable application of, clearly established Supreme Court holdings.
- When the governing Supreme Court rule is general and fact-dependent, state courts have latitude; federal courts may not grant habeas relief merely because they would have reached a different result on de novo review.
- As of the relevant time, Supreme Court holdings did not clearly establish that a suspect’s age and inexperience must be treated as required inputs to the Miranda custody analysis for AEDPA purposes.

## Conclusion

The Court held that, applying AEDPA deference, the state court reasonably concluded that a 17-year-old questioned at a station without Miranda warnings was not in custody, because clearly established Supreme Court precedent did not require explicit consideration of age and inexperience in the Miranda custody inquiry on federal habeas review.


Yarborough v. Alvarado, 541 U.S. 652 (2004)