Yarborough v. Alvarado

17-year-old Alvarado (defendant) helped Soto steal a truck at gunpoint; Soto shot and killed the victim, and Alvarado helped hide the gun. Police interviewed Alvarado for two hours at the station after his parents brought him in and waited outside; he was not given Miranda warnings and ultimately confessed after being urged to tell the truth. His motion to suppress the confession was denied because the interview was deemed noncustodial, and he was convicted. The Ninth Circuit granted habeas relief, holding the trial court should have factored in Alvarado's age and inexperience when assessing whether a reasonable person would have felt free to leave.

Whether the reasonable-person standard of the Miranda custody test requires courts to consider a suspect's age.