Seventeen-year-old Michael Alvarado claimed that his statements made during a police interview should not be used in court because no Miranda warnings were given. He argued that the court should consider his age when determining whether his rights should have been read to him prior to questioning. The trial court relied on his admissions, and Alvarado was convicted of second-degree murder and attempted robbery. On direct appeal, the state court ruled that Alvarado had not been in custody so no warning was required.
Alvarado then filed for a writ of habeas corpus in the United States District Court for the Central District of California. The District Court agreed with the state court that Alvarado had not been in custody. The Court of Appeals for the Ninth Circuit reversed, holding that Alvarado’s youth and inexperience were relevant to the Miranda analysis. Juvenile Law Center filed an amicus brief in the United States Supreme Court in support of the Ninth Circuit’s decision to take Alvarado’s youth and inexperience into account.
On June 1, 2004, the United States Supreme Court reversed the Ninth Circuit and held that, given the fact that this issue was raise on habeas, the court could not conclude that the trial court unreasonably applied the law and that fair-minded jurists could disagree over whether Alvarado was in custody.
In a subsequent case brought on direct appeal, J.D.B. v. North Carolina, the U.S. Supreme Court held that age is indeed a factor in the Miranda analysis.