Dickerson v. United States

Dickerson v. United States Case Brief

United States Supreme Court
530 U.S. 428 (2000)

ISSUE: Was Miranda a constitutional decision such that a state enacted by Congress essentially overruling it is invalid?
HOLDING: Yes.
PROCEDURAL HISTORY:
  • Dickerson was indicted for bank robbery, conspiracy, and using a firearm in violation of the USC
  • Dist. Ct. granted his motion to suppress statements made at the FBI because he was not advised of hisMiranda rights
  • Ct. App. reversed holding that while no Mirandarights were given, USC 3501 only required that the statements had been voluntarily given in order to be admitted into evidence
REASONING:
  • Miranda is a constitutional rule: Congress may not legislatively supersede decisions interpreting and applying the Constitution
    • Miranda began being applied to the states and has continued that way
    • Miranda Court granted cert. to give concrete constitutional guidelines for law enforcement agencies and courts to follow
    • Court left open the possibility that legislation could differ from Miranda warnings if at least as effective in apprising the accused of his rights
    • Exceptions to Miranda only show that no constitutional rule is immutable
  • Statute insufficient: While Sec. 3501 includes as a factor a person's Miranda rights, it does not require them, and the other factors in the statute are not an adequate substitute
    • Statute's totality of the circumstances test is more difficult than Miranda's bright-line test to conform to
DISSENT:
  • It's a frightening antidemocratic power to not merely to apply the Constitution but to impose prophylactic restrictions upon Congress and the States
  • Miranda is objectionable because the Constitution is not offended when a criminal fully aware of his rights but having not received Miranda's warnings makes a voluntary statement
  • The statute does not violate the Constitution becauseMiranda's requirements are extra-constitutional
  • There's little harm in admitting that Miranda was a mistake
COMMENTS:
  • Dickerson is about as close as the Supreme Court is going to get at saying that Miranda was at least rooted in the Constitution. As was discussed following the Miranda v. Arizona case brief, Miranda's safeguards are "prophylactic," meaning that they are just intended to protect a suspect's Fifth Amendment right against compelled self-incrimination. However, while Miranda is a constitutional decision (we learn this from Dickerson), it was not required by the Constitution.
  • So why is that an important distinction? Well, Miranda was certainly broad-sweeping in its universal, bright-line, sine qua non requirement for admissibility of an in-custody confession. The decision was and is heavily criticized for being too broad and not sufficiently rooted in case law or the Constitution. Thus, the Court has since retreated in several respects on the once very strong protections afforded by Miranda warnings. Since Miranda was not required by the Constitution, the Court is able to continue to erode it.
  • What does Dickerson mean? Well Dickerson essentially says, "Hands off, Congress. Miranda is ours." That's really all it's about. Congress cannot, consistent with the Constitution, legislatively supersede a Supreme Court decision interpreting the Constitution. The Court finally claimed Miranda as a constitutional decision, and therefore Congress can't touch it.

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