Michael Yeager Murder Case

Respondent Michael C. was implicated in the murder of Robert Yeager. The murder occurred during a robbery of the victim's home on January 19, 1976. A small truck registered in the name of respondent's mother was identified as having been near the Yeager home at the time of the killing, and a young man answering respondent's description was seen by witnesses near the truck and near the home shortly before Yeager was murdered.

Police took 16.5 year old Michael C. which was also on probation in juvenile court into custody. Michael C. had been on probation since the age of 12. Approximately one year earlier, he had served a term in a youth corrections camp under the supervision of the Juvenile Court. He had a record of several previous offenses,

including burglary of guns and purse snatching, stretching back over several years.
Two police officers began to interrogate him. The officers and respondent were the only persons in the room during the interrogation. The conversation was tape-recorded. One of the officers initiated the interview by informing respondent that he had been brought in for questioning in relation to a murder. The officer fully advised respondent of his Miranda rights.
Michael requested to speak to his probation officer at the outset of the interrogation.

Already on probation with the juvenile court with several prior offenses, Michael sought advice from his probation officer before discussing the present case with officers. His request was denied. Thereafter, Michael agreed to speak with officers without an attorney present, waiving his right to counsel. He proceeded to make incriminating statements and produce sketches that were similarly incriminating. At his murder trial in Juvenile Court, Michael moved to suppress his statements and sketches, arguing that his request to speak to his probation officer constituted an invocation of his Fifth Amendment right to remain silent. The court denied his motion, concluding that Michael had waived his right to remain silent. On appeal, the California Supreme Court reversed, concluding that Michael’s request to see his probation officer constituted a per se invocation of his Fifth Amendment rights just as if he had requested an attorney. That Court also based its determination on state law requirements that probation officers represent the interests of juveniles, concluding that a probation officer fulfills a special role and juveniles may likely turn to their probation officers when dealing with police. Kenneth Fare, as acting chief probation officer, appealed on behalf of the State of

California.
The main issue is whether a juvenile defendant’s request to speak to his probation officer serves as an invocation of his Fifth Amendment right to remain silent?
The Supreme Court has ruled no, probation officers are fundamentally different than attorneys in the criminal justice system, and requesting to speak to a probation officer is not the same as requesting to speak to an attorney.
The California Supreme Court erred in finding that respondent's request for his probation officer was a per se invocation of his Fifth Amendment rights under Miranda, and therefore also erred in holding that, because the police did not cease interrogating respondent the statements and sketches made during the interrogation should have been suppressed.
The rule in Miranda that, if an accused indicates in any manner that he wishes to remain silent or to consult an attorney, interrogation must cease, was based on the unique role the lawyer plays in the adversary system of criminal justice. A probation officer is not in a position to offer the type of legal assistance necessary to protect the Fifth Amendment rights of an accused undergoing custodial interrogation that a lawyer can offer.
The fact that a relationship of trust and cooperation might exist between a probation officer and a juvenile does not indicate that the officer is capable of rendering effective legal advice sufficient to protect the juvenile's rights during police interrogation, or of providing the other services rendered by a lawyer.