The US Supreme Court has declined an invitation to create a special rule for advising juvenile suspects of their Miranda rights prior to an interrogation. In a 5 to 4 decision announced Tuesday, the high court said that criminal suspects who are juveniles are not entitled to more deferential treatment than adult suspects in terms of when Miranda warnings are issued.
The decision reverses an earlier ruling by the Ninth US Circuit Court of Appeals in San Francisco that had overturned the conviction of a 17-year-old involved in a 1995 murder. The majority justices rejected the Ninth Circuit's reasoning, saying the appeals court had overstepped its authority. "The Court of Appeals was nowhere close to the mark," writes Justice Anthony Kennedy for the majority.
The appeals court had ruled that juvenile suspects are entitled to more deferential treatment in terms of Miranda warnings because of their relatively young age and lack of prior experience with law-enforcement officials.
In rejecting that proposition, Justice Kennedy says the appeals court misapplied the requirements of the federal Antiterrorism and Effective Death Penalty Act. The 1996 law requires federal courts to avoid involvement in state court cases except in the rare circumstances when the state court's actions amount to "an unreasonable application of clearly established law."
"We conclude that the state court's application of our clearly established law was reasonable," Justice Kennedy writes.
In a dissent, Justice Stephen Breyer says that "ordinary common sense" suggests that a more deferential approach to Miranda warnings is necessary for younger suspects.
The decision stems from the case of Michael Alvarado, who at 17 was involved with friends in the murder and robbery of a truck driver in Santa Fe Springs, Calif. A month after the killing, a police detective arranged for the teen to be brought in for questioning. He was not placed under arrest, nor warned that he had a right to remain silent and consult a lawyer. Alvarado was questioned for two hours and made incriminating statements that were later used as evidence at his trial. He was convicted of second-degree murder and attempted robbery.
Alvarado attacked his conviction by claiming on appeal that his statements made to police should not have been admitted as evidence because they were obtained prior to his being advised of his Miranda rights. The state appeals court and a federal judge rejected this claim. But a Ninth Circuit panel agreed with Alvarado, ruling that as a juvenile he should have been issued Miranda warnings prior to the questioning.