Harris v. New York

Harris v. New York Case Brief

United States Supreme Court
401 U.S. 222 (1971)

ISSUE: Can the prosecution use a statement obtained in violation of Miranda to impeach the D's testimony at trial?
HOLDING: Yes.
PROCEDURAL HISTORY:
  • D was indicted for 2x selling narcotics to undercover officers
  • 1 officer testified about the sales, another confirmed collateral details, and a 3rd testified as to the chemical analysis of the heroin
  • D then took the stand and testified that he sold baking powder, not heroin
  • Prosecution then impeached him with statements made to arresting officers in violation of Miranda
  • Ct. App. affirmed conviction
REASONING:
  • Impeachment allowed: The impeachment process undoubtedly provided valuable aid to the jury in assessing D's credibility, and the benefits of this process should not be lost because of the speculative possibility that impermissible police conduct will be encouraged thereby
    • Sufficient deterrence flows from the evidence in question being inadmissible in the case-in-chief
    • D not entitled to perjure himself, and the prosecution did no more than utilize the traditional truth-testing device
DISSENT - Brennan:
  • Miranda settled that "exculpatory" incriminating statements are still incriminating and can't be used in violation of the Miranda rule
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