Miranda v. Arizona

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Miranda v. Arizona
Reference: 384 U.S. 436
Term: 1966
Important Dates
Argued: February 28, 1966 Decided: June 13, 1966
Outcome
Supreme Court of Arizona reversed
Majority
Chief Justice Earl Warren • Hugo Black • William Brennan • Tom Clark • William Douglas • Abe Fortas
Concurring
Tom Clark
Dissenting
John M. Harlan • Potter Stewart • Byron White

Miranda v. Arizona is a case decided on June 13, 1966, by the U.S. Supreme Court, which ruled that statements obtained from suspects in police custody were not permissible in court unless police informed suspects that their statements could be used to prosecute them in court and made suspects aware of their constitutional rights against self-incrimination (to remain silent) and to obtain an attorney (or have one appointed to them by the state).

The case concerned the validity of a criminal conviction based partially on a confession police obtained during an interrogation in which they did not inform the suspect of his constitutional right against self-incrimination under the Fifth Amendment or his right to an attorney under the Sixth Amendment, as incorporated under the Due Process Clause of the Fourteenth Amendment. The U.S. Supreme Court reversed the decision of the Arizona Supreme Court and ordered a retrial of the case, holding that the confession was obtained unconstitutionally and was not admissible in court.

HIGHLIGHTS

The case: Ernesto Miranda was arrested for allegedly kidnapping and raping a woman. The police questioned him for two hours and obtained a written confession of the crime that Miranda signed. Miranda's lawyer objected to the confession being entered at trial because the interrogators had not informed Miranda that he had a right to counsel during police questioning. The objection was overruled, and Miranda was convicted, based partially on the confession.

The issue: Does the constitutional right against self-incrimination under the Fifth Amendment or the right to an attorney under the Sixth Amendment, as incorporated under the Due Process Clause of the Fourteenth Amendment, require police to advise suspects of their rights before collecting statements or confessions to use against them in court?

The outcome: The Supreme Court held that confessions obtained from suspects who were not informed of their Fifth and Sixth Amendment rights were not admissible in court.

Why it matters: The Supreme Court held that statements obtained from suspects in police custody were not permissible in court unless police informed suspects that their statements could be used to prosecute them in court and made suspects aware of their constitutional rights against self-incrimination (under the Fifth Amendment) and to obtain an attorney or have one appointed to them by the state (under the Sixth Amendment). Chief Justice Earl Warren in the majority opinion said, "After such warnings have been given, and such opportunity afforded him, the individual may knowingly and intelligently waive these rights and agree to answer questions or make a statement. But unless and until such warnings and waiver are demonstrated by the prosecution at trial, no evidence obtained as a result of interrogation can be used against him."

Background

Legal background

In 1964, the U.S. Supreme Court announced its opinion in Escobedo v. Illinois (378 U.S. 478). Danny Escobedo was arrested and charged with the murder of his brother-in-law, Manuel Valtierra. Police attempted to interrogate Escobedo, but, on advice of counsel, Escobedo refused to make any statements. He was subsequently released. A week later, another suspect who was in police custody, Benedict DiGerlando, informed police that Escobedo shot his brother-in-law because of Valtierra's alleged mistreatment of Escobedo's sister. Based on DiGerlando's information, police arrested both Escobedo and his sister. En route to the police station, police attempted to get Escobedo to make a statement, but Escobedo refused and requested to see his attorney, who was at the police station. The police refused and proceeded to question Escobedo for over 14 hours until Escobedo made incriminating statements. Based in part on this evidence, Escobedo was convicted of murder.

In his opinion for the court reversing Escobedo's conviction, Justice Arthur Goldberg held that the right to counsel began during the accusatory stage of an investigation when a police inquiry focused on a particular individual (or individuals) for a specific crime (or crimes).

“

Where ... the investigation is no longer a general inquiry into an unsolved crime but has begun to focus on a particular suspect, the suspect has been taken into police custody, the police carry out a process of interrogations that lends itself to eliciting incriminating statements, the suspect has requested and been denied an opportunity to consult with his lawyer, and the police have not effectively warned him of his absolute constitutional right to remain silent, the accused has been denied 'the Assistance of Counsel' in violation of the Sixth Amendment to the Constitution ... and that no statement elicited by the police during the interrogation may be used against him at a criminal trial. ... We hold only that when the process shifts from investigatory to accusatory - when its focus is on the accused and its purpose is to elicit a confession - our adversary system begins to operate, and, under the circumstances here, the accused must be permitted to consult with his lawyer.

”

Case background

Four cases were consolidated for argument before the U.S. Supreme Court. In addition to Miranda, the court heard arguments in Vignera v. New York, Westover v. U.S., and California v. Stewart.

Around March 3, 1963, Ernesto Miranda allegedly kidnapped and raped a young woman near Phoenix, Arizona. On March 13, 1963, Miranda was arrested at his home and was taken in custody to a Phoenix police station. While in custody, Miranda was recognized by the complaining witness, at which point Miranda was interrogated by two police officers. After two hours of questioning, police obtained a written confession signed by Miranda. At the top of the confessional statement "was a typed paragraph stating that the confession was made voluntarily, without threats or promises of immunity and 'with full knowledge of my legal rights, understanding any statement I make may be used against me.'"

At trial, Miranda's written confession was entered into evidence over the objection of Miranda's court-appointed lawyer. The two officers testified that, although Miranda had orally confessed, this confession had been made without the officers advising Miranda of his right to counsel. Miranda did not request an attorney at any point during his interrogation. Based in part on this confession, Miranda was convicted at trial of kidnapping and rape and was sentenced to 20 to 30 years imprisonment on each count, with the sentences to run concurrently. In affirming the convictions, the Supreme Court of Arizona held that Miranda's constitutional rights were not violated in obtaining the confession. Miranda appealed to the U.S. Supreme Court.

Oral argument

Oral argument was conducted on February 28, 1966. The case was decided on June 13, 1966.

Decision

The U.S. Supreme Court reversed the judgment of the Supreme Court of Arizona and held that confessions obtained from suspects who were not informed of their Fifth and Sixth Amendment rights were not admissible in court.

Opinions

Opinion of the court

Chief Justice Warren wrote the opinion for a five-justice majority, joined by Justices Black, Brennan, Douglas, and Fortas. Warren said the court would address "the admissibility of statements obtained from an individual who is subjected to custodial police interrogation and the necessity for procedures which assure that the individual is accorded his privilege under the Fifth Amendment to the Constitution not to be compelled to incriminate himself."

Examination of precedent

Chief Justice Warren argued the court's opinion in Miranda was a logical extension of the court's 1964 opinion in Escobedo and was consistent with the historical view the court had taken of the constitutional protection against self-incrimination and the right to the effective assistance of counsel, citing the court's opinions in Brown v. Walker (1896), Weems v. United States (1910), and Silverthorne Lumber Co. v. United States (1920): "We start here, as we did in Escobedo, with the premise that our holding is not an innovation in our jurisprudence, but is an application of principles long recognized and applied in other settings. ... These precious rights were fixed in our Constitution only after centuries of persecution and struggle. And in the words of Chief Justice Marshall, they were secured 'for ages to come, and ... designed to approach immortality as nearly as human institutions can approach it.'"

Warren argued that each of the cases cited included examples of "incommunicado interrogation of individuals in a police-dominated atmosphere, resulting in self-incriminating statements without full warnings of constitutional rights" and that "an understanding of the nature and setting of this in-custody interrogation" was essential to understanding the court's actions resulting from the opinion. Chief Justice Warren said the court "recognized that coercion can be mental as well as physical, and that the blood of the accused is not the only hallmark of an unconstitutional inquisition."

Examination of police interrogation techniques

The court examined a sampling of police training manuals on interrogation techniques and argued they were coercive and imposed a heavy burden on the protection against self-incrimination:

“

From these representative samples of interrogation techniques, the setting prescribed by the manuals and observed in practice becomes clear. In essence, it is this: To be alone with the subject is essential to prevent distraction and to deprive him of any outside support. The aura of confidence in his guilt undermines his will to resist. He merely confirms the preconceived story the police seek to have him describe. Patience and persistence, at times relentless questioning, are employed. To obtain a confession, the interrogator must 'patiently maneuver himself or his quarry into a position from which the desired objective may be attained.' When normal procedures fail to produce the needed result, the police may resort to deceptive stratagems such as giving false legal advice. It is important to keep the subject off balance, for example, by trading on his insecurity about himself or his surroundings. The police then persuade, trick, or cajole him out of exercising his constitutional rights. Even without employing brutality, the 'third degree' or the specific stratagems described above, the very fact of custodial interrogation exacts a heavy toll on individual liberty and trades on the weakness of individuals. ... It is obvious that such an interrogation environment is created for no purpose other than to subjugate the individual to the will of his examiner. This atmosphere carries its own badge of intimidation. To be sure, this is not physical intimidation, but it is equally destructive of human dignity. The current practice of incommunicado interrogation is at odds with one of our Nation's most cherished principles - that the individual may not be compelled to incriminate himself. Unless adequate protective devices are employed to dispel the compulsion inherent in custodial surroundings, no statement obtained from the defendant can truly be the product of his free choice.

”

The Miranda warnings

Chief Justice Warren argued that, based on the court's analysis of police interrogation techniques and previous cases, law enforcement officers needed to follow certain procedures to ensure the Fifth Amendment's protection against self-incrimination was respected during custodial interrogations. Warren outlined what are today known as the Miranda warnings or Miranda rights, which are the series of rights police officers must inform suspects of before attempting to elicit incriminating statements:

“

When an individual is taken into custody or otherwise deprived of his freedom by the authorities in any significant way and is subjected to questioning, the privilege against self-incrimination is jeopardized. Procedural safeguards must be employed to protect the privilege, and unless other fully effective means are adopted to notify the person of his right of silence and to assure that the exercise of the right will be scrupulously honored, the following measures are required. He must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires. Opportunity to exercise these rights must be afforded to him throughout the interrogation. After such warnings have been given, and such opportunity afforded him, the individual may knowingly and intelligently waive these rights and agree to answer questions or make a statement. But unless and until such warnings and waiver are demonstrated by the prosecution at trial, no evidence obtained as a result of interrogation can be used against him.

”

Reversal of Miranda's conviction

After announcing the guidelines, the court reversed the Supreme Court of Arizona, finding that "from the testimony of the officers and by the admission of respondent, 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. Without these warnings the statements were inadmissible. The mere fact that he signed a statement which contained a typed-in clause stating that he had 'full knowledge' of his 'legal rights' does not approach the knowing and intelligent waiver required to relinquish constitutional rights."

Clark's dissent in part and concurrence in part

Justice Clark argued that the majority's opinion went "too far on too little." He said the majority's interpretation of the Fifth Amendment and the creation of Miranda warnings were arbitrary:

“

Rather than employing the arbitrary Fifth Amendment rule which the Court lays down I would follow the more pliable dictates of the Due Process Clauses of the Fifth and Fourteenth Amendments which we are accustomed to administering and which we know from our cases are effective instruments in protecting persons in police custody. In this way we would not be acting in the dark nor in one full sweep changing the traditional rules of custodial interrogation which this Court has for so long recognized as a justifiable and proper tool in balancing individual rights against the rights of society. It will be soon enough to go further when we are able to appraise with somewhat better accuracy the effect of such a holding.

”

Harlan's dissenting opinion

Justice Harlan argued that the Fifth Amendment's protections against self-incrimination applied only in courts and did not extend to the police station: "The Court's opinion in my view reveals no adequate basis for extending the Fifth Amendment's privilege against self-incrimination to the police station. Far more important, it fails to show that the Court's new rules are well supported, let alone compelled, by Fifth Amendment precedents. Instead, the new rules actually derive from quotation and analogy drawn from precedents under the Sixth Amendment, which should properly have no bearing on police interrogation."

Justice Harlan also rejected the court's reasoning on policy grounds, referring to the court's Miranda warning requirement as "a hazardous experimentation." Justice Harlan wrote that "nothing in the letter or the spirit of the Constitution or in the precedents squares with the heavy-handed and one-sided action that is so precipitously taken by the Court in the name of fulfilling its constitutional responsibilities."

White's dissenting opinion

Justice White argued the court's decision would weaken the criminal process, make it harder for police to collect evidence to convict criminals, and increase the number of trials in courts by reducing the number of guilty pleas:

“

This is the not so subtle overtone of the opinion - that it is inherently wrong for the police to gather evidence from the accused himself. And this is precisely the nub of this dissent. I see nothing wrong or immoral, and certainly nothing unconstitutional, in the police's asking a suspect whom they have reasonable cause to arrest whether or not he killed his wife or in confronting him with the evidence on which the arrest was based, at least where he has been plainly advised that he may remain completely silent. ... The rule announced today will measurably weaken the ability of the criminal law to perform these tasks. It is a deliberate calculus to prevent interrogations, to reduce the incidence of confessions and pleas of guilty and to increase the number of trials. ... I have no desire whatsoever to share the responsibility for any such impact on the present criminal process.

”

Impact

The Supreme Court's decision in Miranda and the establishment of the Miranda warnings led law enforcement agencies to adopt the procedure of reading suspects their rights when they are arrested or brought into custody. Miranda made it commonplace for police to inform arrestees that they have the right to remain silent, that anything they say can be used against them in a court of law, and that they have the right to the presence of an attorney (and that one will be provided for them if necessary).

In 2000, the court in Dickerson v. United States held that "Miranda and its progeny in this Court govern the admissibility of statements made during custodial interrogation in both state and federal courts." Writing for a seven-justice majority, Chief Justice William Rehnquist acknowledged that "Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture."

Aftermath

After the reversal of his conviction, Miranda was retried as "Joe Gomez" in order to protect his identity and with his incriminating statements excluded at trial. He was convicted again at trial largely due to the testimony of Miranda's common-law wife, who stated under oath that Miranda admitted to her that he abducted and raped the victim. He was also convicted of an unrelated robbery of a woman. He received a sentence of 20 to 30 years for the kidnapping and rape and a sentence of 20 to 25 years for the robbery. In December 1972, Miranda was released on parole.

See also

• Supreme Court of the United States
• History of the Supreme Court

External links

• Supreme Court of the United States