Yarborough v. Alvarado

17-year-old Michael Alvarado (defendant) agreed to help Paul Soto (defendant) steal Francisco Castaneda’s truck. Soto demanded Castaneda’s money and keys at gunpoint while Alvarado waited on the passenger side. Soto shot and killed Castaneda, and Alvarado helped hide the gun. Police requested a meeting, and Alvarado’s parents took him to the station for the two-hour interview. Alvarado’s parents claim that police would not allow them to be present for the interview. Alvarado was not given the Miranda warnings. The interviewer encouraged Alvarado to tell the truth, and Alvarado ultimately confessed. Months later, Alvarado was arrested for robbery and murder. Alvarado made a pretrial motion to suppress his statements. The motion was denied since the statements were made during a noncustodial interview. A jury found Alvarado guilty of first-degree murder and attempted robbery, but the judge reduced the charge to second-degree murder and sentenced Alvarado to 15 years to life imprisonment. The appellate court affirmed the conviction. Alvarado petitioned for habeas corpus in federal district court. The district court denied the petition. The United States Court of Appeals for the Ninth circuit reversed on the grounds that the trial court did not consider Alvarado’s age and inexperience in its determination that a reasonable person would have felt free to terminate the interview. The United States Supreme Court granted certiorari.