Do you agree with the Supreme Court’s ruling in Yarborough v. Alvarado?

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Whether you might agree with the court's majority ruling depends on if you feel that relying on subjective factors to define police custody muddies the waters of legal situations. You might disagree with the ruling if you feel that it is reasonable to assume that Alvarado had every right to believe that he was in police custody at the time of his interrogation and that relying on police to interpret these situations by objective factors could lead to abuse.

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The other educator's answer argues that the Supreme Court's majority ruling is a correct one. For the sake of an argument, I will present why someone might disagree with it.

No two arrests are the same. There are numerous subjective factors that come into play which have a significant impact on criminal proceedings. While it may be clear to the police whether or not a suspect is in custody, there are numerous societal, cultural, and psychological factors that might make that unclear to the suspect.

In his dissent, Justice Breyer wrote that a suspect can effectively be in custody without it meeting all the objective stipulations that make it technically so. It is clear that Alvarado did not feel that he was at liberty to simply get up and terminate the interrogation. Therefore, even though the police might not have considered him to be in custody, Alvarado clearly did.

This case asked law enforcement to apply common sense interpretations of what it meant to be in custody, not apply some complex legal standard. By relying on the police to determine if a suspect is in their custody, that allows them to apply the suspect's Fifth Amendment rights at their discretion. In other words, it becomes too easy for the police to manipulate the situation to their advantage if they deem that the suspect is ignorant of their actual situation and the nuances of the law. In the particular case of Alvarado, it is reasonable to assume that he felt that he was under police custody, and the police had the responsibility to recognize that and inform him of his actual situation.

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Yarborough v. Alvarado (2004) was a civil liberties case decided by the US Supreme Court. The question before the court was whether a law enforcement officer needs to take into consideration certain subjective factors, such as the suspect's age and criminal history, in determining whether he or she is "in custody," for the purposes of reading them their Miranda rights.

In the landmark case of Miranda v. Arizona (1966), the Supreme Court ruled that law enforcement officers are required to inform an in-custody suspect of his or her constitutional rights, stated under the Fifth Amendment. If they fail to do this, then any subsequent statements made by a suspect will not be admissible in a court of law.

In Yarborough, the respondent, Michael Alvarado, was a young adult interviewed by police concerning his involvement in a crime. He wasn't formally arrested and he was not read his Miranda rights. Yet, during the interview, he confessed to his involvement in the crime. Subsequently convicted of second-degree murder and robbery, he appealed his conviction on the basis that, as he felt he was in custody, he was entitled to protection under the Fifth Amendment as established in Miranda. Initially, Alvarado was unsuccessful in his appeal but prevailed when his case came before the Ninth Circuit Court of Appeals. Yarborough then challenged the Court's verdict and the case was sent up to the US Supreme Court.

By a 5-4 majority, the Court ruled that the test of whether or not a suspect is in custody is an objective, not a subjective, one. In other words, even if the suspect genuinely believes that he or she is in custody, there still must be objective criteria in place to determine whether or not he or she actually is. It is only if these objective criteria are met that the police should read suspects their Miranda rights. Therefore, Alvarado's original criminal conviction was sound.

On the whole, I would argue that the Court's decision is correct. For one thing, it is an accurate interpretation of Miranda. The whole point of that ruling was to establish clear, objective standards that law enforcement officers could easily follow. Despite a good deal of criticism from the law enforcement community, there's evidence to suggest that Miranda has led to greater efficiency in the handling of cases and to a higher number of convictions as a consequence.

If subjective factors are taken into consideration, however, then the picture becomes somewhat blurred. Alvarado believed that he was in custody when in actual fact he wasn't. The Ninth Court of Appeals, in ruling in favor of Alvarado, held that young people of his age were more likely to feel that they were in custody and that subjective factors, such as his, were relevant in determining the necessary conditions for the reading of Miranda warnings.

The Supreme Court disagreed with this reasoning, and I would concur. Using subjective criteria such as a suspect's age simply adds confusion to an otherwise straightforward situation. If objective criteria can be established beforehand, then both law enforcement officers and suspects know exactly where they stand. Introducing subjective criteria into the mix makes it more difficult for everyone concerned to follow the correct procedure, potentially leading to both miscarriages of justice and criminals going free. The Supreme Court's ruling in Miranda related to the objective procedure of police interrogation, not the suspect's individual interpretation of what's going on. On that basis, I would argue that the majority of the Court made the correct decision.

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