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Under the "unreasonable application" clause of 28 U.S.C.S. § 2254(d)(1), a federal habeas court may grant the writ if the state court identifies the correct governing principle from the United States Supreme Court's decisions but unreasonably applies that principle to the facts of the prisoner's case. The term "unreasonable" is a common term in the legal world and, accordingly, federal judges are familiar with its meaning. At the same time, the range of reasonable judgment can depend in part on the nature of the relevant rule. If a legal rule is specific, the range may be narrow. Applications of the rule may be plainly correct or incorrect. Other rules are more general, and their meaning must emerge in application over the course of time. Applying a general standard to a specific case can demand a substantial element of judgment. As a result, evaluating whether a rule application was unreasonable requires considering the rule's specificity. The more general the rule, the more leeway courts have in reaching outcomes in case by case determinations.
Respondent Alvarado, a 17-year-old suspect, who had allegedly participated in a shooting and an attempted robbery, was called in to a California county sheriff's station for an interview. Respondent’s parents brought him to the station and waited in the station's lobby during the 2-hour interview, at which the parents were not present. The interview was conducted by a sheriff's detective, who did not give respondent the warnings required by Miranda v Arizona (1966) 384 US 436, 16 L Ed 2d 694, 86 S Ct 1602; focused not on the respondent’s alleged crimes, but rather on those of another person who had allegedly done the shooting; appealed to the respondent’s interest in telling the truth and being helpful to a police officer; and twice asked the respondent if he wanted to take a break. Although the respondent at first denied being present at the shooting, he ultimately admitted that he had helped the other person try to steal the shooting victim's truck and to hide the person's gun after the shooting. At the end of the interview, the respondent went home. The respondent was subsequently charged with first-degree murder and attempted robbery. A California trial court, concluding that the respondent’s interview had been noncustodial for purposes of Miranda, denied the respondent's motion to suppress the statements that he had made at the interview. Ultimately, the respondent was convicted of second-degree murder and sentenced to prison. The state court found that an advisement of rights was not required since the inmate was not in custody at the time of the questioning, but the lower federal appellate court found that the state court unreasonably applied federal law, within the meaning of § 2254(d)(1), by failing to consider the age and inexperience of the inmate in determining that the interrogation was not custodial.
Was the respondent in custody for Miranda purposes during his police interview?
The Court held that the state court considered the proper factors and reached a reasonable conclusion that Alvarado was not in custody for Miranda purposes during his police interview. Although some facts weighed in favor of the view that the respondent had been in custody, other facts weighed against such a finding, as those facts were consistent with an interrogation environment in which a reasonable person would have felt free to terminate the interview and leave. In the circumstances presented, fair-minded jurists could have disagreed as to whether the respondent was in custody under the Supreme Court's general standard for determining custody, and the state court's application of the Supreme Court's law was reasonable and fit within the matrix of the Supreme Court's prior decisions. The Court held that the state court's failure to consider the suspect's age did not provide a proper basis for finding that the state court's decision was an unreasonable application of clearly established law.