Michael Alvarado helped his friend Paul Soto steal a truck in Santa Fe Springs, California.

The truck owner was killed by Soto during the robbery and Alvarado was convicted of second-degree murder for his role in the crime.

Alvarado appealed his conviction, claiming that the determination that he was not in custody was incorrect because the courts did not take his age into account.

The respondent Michael Alvarado agreed to help his friend Paul Soto steal a truck in the parking lot of a shopping mall in Santa Fe Springs, California.

The trial court denied the motion on the basis that Alvarado was not in police custody at the time he gave his statement.

[4] Alvarado's conviction was reduced by the trial judge to second-degree murder for his comparatively minor role in the offense.

[7] Alvarado's habeas corpus petition thus depended on demonstrating that the state court's custody determination was more than debatable, but objectively incorrect.

[9] Chief Justice William Rehnquist noted early in the oral argument that the case presented two questions.

[10] California Deputy Attorney General Deborah Chuang argued that the Ninth Circuit's ruling was not consistent with precedent because the Supreme Court had never addressed using age as a factor in custody analysis.

[12] John P. Elwood, at the time assistant to the Solicitor General, argued that age doesn't make a legal difference for Miranda purposes because it is a rule uniformly applied to all people[13] and that police officers should not be required to get inside the head of each suspect.

[14] Tara K. Allen, arguing for Alvarado, claimed that the state court's decision was objectively unreasonable because they did not consider the totality of the circumstances surrounding the investigation as required by Thompson v.

Associate Justice Antonin Scalia responded by saying that, according to Thompson v. Keohane, custody is an objective test[17] and subjective factors like characteristics of the individual do not matter.

[22] Central to the reversal of the Ninth Circuit was the fact that the state court did not take into account Alvarado's age and experience with law enforcement in the custody analysis.

[23] Associate Justice Sandra Day O'Connor wrote a concurrence that agreed with the finding that the state court's decision was reasonable.

The note argued that establishing such broad legal precedent was outside the bounds of the authority of the Ninth Circuit and the Supreme Court was right to reverse.

[31] Berry Feld, professor at University of Minnesota Law School, wrote: "the Court's decision ... treated juveniles as the functional equals of adults during interrogation.

Over the past quarter-century, developmental psychological research consistently has emphasized adolescents' inability to understand or exercise Miranda rights".

[32] Paul Holland, professor at Seattle University School of Law, wrote that "the assumptions Justice Kennedy made in Alvarado are inapplicable to the schoolhouse context ... considering the age of a student-suspect questioned at school, would not present a significant risk of compromising the clarity the Court has sought to provide law enforcement.