Rhode Island v. Innis

Rhode Island v. Innis Case Brief

United States Supreme Court
446 U.S. 291 (1980)

ISSUE: Was an individual "interrogated" under Miranda if the 2 officers in the police car said that it would be unfortunate for a little handicapped girl to die by finding a sawed-off shotgun hidden by the individual?
HOLDING: No.
FACTS:
  • A taxicab driver was found buried in a shallow grave
  • Another driver reported that he had just been assaulted in his taxicab and had just dropped off the assailant and went to the police to make a statement
  • At the police station, the driver noticed a photo of D and then picked D's photo out of a photo lineup
  • When an officer on patrol noticed D, he arrested him and Mirandized him. D was Mirandized several more times, and D requested an attorney
  • In the patrol car with 3 officers, 2 of them began to say that it would be terrible if a young girl were hurt or killed after finding the lost sawed-off shotgun
  • D then told them to turn the car around and told them where the gun was
PROCEDURAL HISTORY:
  • Grand jury indicted D with kidnapping, robbery, and murder
  • Trial judge refused to suppress the shotgun finding that he had repeatedly been Mirandized, it was entirely understandable for the officers to voice their concern for the safety of handicapped children, and D's statement was a clear and intelligent waiver of hisMiranda rights
  • RI Sup. Ct. reversed concluding that once D invoked his right to counsel, all custodial interrogation should have ceased
    • Officers' statements had been "subtle coercion," which was the equivalent of "interrogation" within the meaning of Miranda
RULES:
  • Miranda v. Arizona: By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.
REASONING:
  • Not narrow meaningMiranda "interrogation" should not be construed so narrowly as only to include direct questioning
    • Police practices that evoked the concerns inMiranda included several that did not involve express questioning
  • Voluntary statements: Volunteered statements of any kind are not barred by the 5th Amdt. or Miranda, so there must be some measure of compulsion above and beyond that inherent in custody itself
  • "Interrogation" under MirandaMiranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent
    • Express questioning, AND
    • Any words or actions on the part of the police (other than those normally attendant to an arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the subject
      • Limited to words and actions that the police should have known were reasonably likely to elicit an incriminating response
  • D not "interrogated": D was not interrogated within the meaning of Miranda because it cannot be said that the officers should have known that their conversation was reasonably likely to elicit an incriminating response from D
    • No indication that D was peculiarly susceptible to an appeal to his conscience
    • Not unusually disoriented or upset
    • Nothing more here than a few offhand remarks
DISSENT - Marshall:
  • Utterly at a loss to understand how the objective standard as applied to the facts here can rationally lead to the conclusion that there was no interrogation
  • One can scarcely imagine a stronger appeal to the conscience of a suspect
  • Classic interrogation technique
DISSENT - Stevens:
  • Any statement that would normally be understood by the average listener as calling for a response is the functional equivalent of a direct question, whether or not punctuated by a question mark
    • Should be no requirement of "should have known"
  • Apparent attempts to elicit info from a suspect after he has invoked his right to cut off questioning necessarily demean the right to remain silent and tend to reinstate the imbalance between police and suspect that the warnings were designed to correct
  • Statement here by officers was designed to elicit a response
  • Majority's test creates an incentive for police to ignore a suspect's invocation of rights and continue to attempt to extract info from him
COMMENTS:
  • Innis defines the "interrogation" part of "custodial interrogation," which is the test for when the safeguards of Miranda v. Arizona apply. "Interrogation" for the purposes of Miranda means either express questioning or its functional equivalent. "Functional equivalent" means words and actions the police should know are reasonably likely to elicit an incriminating response from the suspect. As the "should have known" language implies, the test is mostly objective.
  • The rule in Innis is not surprising; it makes sense. "Interrogation" can result either through the use of actual questions or through other means, such as statements and conduct that make the suspect want to confess. If the police know that someone is particularly susceptible to a particular subject and they exploit that susceptibility, that will be "interrogation" under Miranda.
  • How the Court applied its new test to the facts of the present case and came out the way it did is less agreeable. I'm not quite sure that the police would really need to know that a particular person, versus just a person in general, would be susceptible to the ploy used here. Regardless, the law from Innis is really what matters anyway.

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