Miranda v. Arizona

Miranda v. Arizona Case Brief

United States Supreme Court
384 U.S. 436 (1966)

ISSUE: Must a suspect be informed of his constitutional rights against self-incrimination and assistance of counsel and give a voluntary waiver of these rights as a necessary precondition to police questioning and the giving of a confession?
HOLDING: Yes.
FACTS:
  • Miranda was arrested and taken into custody to a police station where he was identified by the complaining witness
  • He was questioned for 2 hours by 2 officers without be advised of his right to counsel and then signed a statement that said that his confession was voluntary
REASONING:
  • Need for limitation: Unless a proper limitation upon custodial interrogation is achieved, there can be no assurance that black police practices of this nature will be eradicated in the foreseeable future
    • Unless adequate protective devices are employed to dispel the compulsion inherent in custodial surroundings, no statement obtained from the D can truly be the product of his free choice
  • 5th Amdt. applies: All the principles embodied in the privilege against self-incrimination apply to informal compulsion exerted by law enforcement officers during in-custody questioning
    • 5th Amdt. privilege applies in all settings where the freedom of the suspect is curtailed in any significant way
    • Does NOT apply to general on-the-scene questioning
  • Required admonition of rights:
    1. Suspect must be informed in clear and unequivocal terms that he has the right to remain silent
      • Absolute prerequisite to overcoming the inherent pressures of the interrogation atmosphere
      • Warning will show that one's interrogators are prepared to recognize his privilege should he choose to exercise it
    2. Anything said can and will be used against the individual in court
      • It is only through awareness of these consequences that there can be any assurance of real understanding and intelligent exercise of the privilege
    3. Individual has a right to consult with counsel and have him present during any questioning if the individual so desires
      • Assistance of counsel can mitigate the dangers of untrustworthiness
      • Presence of a lawyer can guarantee that the accused gives a fully accurate statement to the police
      • Failure to ask for a lawyer does NOT constitute a waiver
    4. If the individual is indigent, a lawyer will be appointed to represent him
      • Without this additional warning, the admonition of the right to consult with counsel would often be understood as meaning only that he can consult with a lawyer if he has one or has the funds to obtain one
      • Financial ability of the individual has no relationship to the scope of the rights involved here
  • Invocation of rights: If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease
    • In the individual states that he wants an attorney, the interrogation must cease until an attorney is present
    • If the interrogation continues without the presence of an attorney and a statement is taken,a heavy burden rests on the govt. to demonstrate that the D knowingly and intelligently waived his privilege against self-incrimination and his right to retained or appointed counsel
    • Whatever the testimony of the authorities as to D's waiver, a lengthy and incommunicado interrogation before a statement is made is strong evidence that the accused did not validly waive his rights
  • Miranda: It is clear that Miranda was not in any way apprised of his right to consult with an attorney and to have one present during the interrogation, nor was his right not to be compelled to incriminate himself effectively protected in any other manner
DISSENT - Harlan:
  • Majority aims for "voluntariness" in a Utopian sense
  • DPC is an adequate tool for coping with confessions
  • 5th Amdt. has never been thought to forbid all pressure to incriminate one's self in the situations covered by it
  • To require an express waiver by the suspect and the assistance of counsel severely restricts interrogation
COMMENTS:
  • This is a case that needs no introduction. Probably every American is familiar with the oft-recited Miranda warnings. We see them on TV and in the movies all the time. You probably already know them by heart or at least are intimately familiar with them. "You have the right to remain silent. Anything you say can and will be used against you in court. You have the right to speak to an attorney and have him present with you during any questioning. If you cannot afford one, one will be appointed to you at no cost." These warnings are the sine qua non (but-for) requirement of a voluntary confession. Without properly admonishing a suspect of his rights before in-custody interrogation, any confession will be automatically deemed "involuntary."
  • Miranda marks the start of a second line of cases attacking confessions. While the Miranda Court paints the decision in terms of involuntariness, it is crucial to understand that a confession that violates Miranda (probably because the warnings were not given or were inadequate) does NOT automatically violate the Due Process Clauses of the Fifth and Fourteenth Amendments. It is so important that I will repeat it: a confession that violates Miranda does NOT necessarily violate the Due Process Clause.
  • Why is this so? Well, the Miranda warnings are "prophylactic," meaning that they are intended to guard a suspect's due process rights. Thus, Miranda stands in front of the Due Process Clause guarding it. Any violation of Miranda will not violate the Due Process Clause unless there is also physical coercion or an "inherently coercive" interrogation environment. When you write a law school exam, you always want to address a possible Due Process violation and a possible Miranda violation. They are similar and necessarily related, but not necessarily dependent on each other.
  • Theoretically the difference between Miranda and the Due Process Clause is a two-way street. A confession could violate Miranda but not violate the Due Process Clause. For example, the police never lay a hand on a suspect and question him in a very friendly atmosphere. The failure to give Miranda warnings renders the confession inadmissible in the prosecution's case-in-chief for being unwarned, but it's not necessarily "involuntary" in due process parlance. Here's the other side of the street: the police adequately warn a suspect of his Miranda rights but then beat him to a pulp and obtain a confession. Technically Miranda has not been violated, but you better bet that the Due Process Clause bars that confession from evidence.
  • Again, Miranda warnings are absolutely a prerequisite for an admissible confession (well, except for the narrow New York v. Quarles exception). They must be given, even if a suspect swears up and down that he knows his rights cold. The police arrest your criminal procedure professor: do they need to "Mirandize" him? Oh yes. Miranda is about as much of a bright-line test as we're ever going to get in criminal procedure.
  • When does Miranda apply? Miranda applies only to custodial interrogation such as when a person is arrested. However, Miranda does not apply to Terry stops or traffic stops (which are essentially Terry stops anyways). This is because of the Court's decision in Berkemer v. McCarty. But don't forget about the second word in the phrase "custodial interrogation." If the police don't "interrogate" a suspect based on the Rhode Island v. Innis definition of "interrogation," no Miranda warnings are necessary.
  • So here's your basic Miranda formula: custody + interrogation = Miranda warnings.

 

Leave a Reply