Miranda v. Arizona

Miranda v. Arizona (consolidated with Westover v. United States, Vignera v. New York, and California v. Stewart), {{ussc|384|436|1966}}, was a landmark 5-4 decision of the United States Supreme Court which was argued February 28–March 1, 1966 and decided June 13, 1966. The Court held that suspects, prior to being interrogated by police, must be informed of their rights under the Fifth and Sixth Amendments to the United States Constitution.

Subsequent history

Since the original decision, courts have ruled that the warning must be "meaningful", so it is usually required that the suspect be asked if he understands his rights. Courts have also ruled that any subsequent waiver of Miranda rights must be knowing, intelligent, and voluntary. Many American police departments have pre-printed Miranda waiver forms which a suspect must sign and date (after hearing and reading the warnings again) if an interrogation is to occur.

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But the words "knowing, intelligent, and voluntary" mean only that the suspect reasonably appears to understand what he is doing, and is not being coerced into signing the waiver; the Court ruled in Colorado v. Connelly (1986) that it is completely irrelevant if the suspect may actually have been insane at the time.

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A confession obtained in violation of the Miranda standards may nonetheless be used for purposes of impeaching the defendant's testimony: that is, if the defendant takes the stand at trial and the prosecution wishes to introduce his confession as a prior inconsistent statement to attack his credibility, the Miranda holding will not prohibit this. (Harris v. New York {{ussc|401|222|1971}})

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A "spontaneous" statement made by a defendant while in custody, even though the defendant has not been given the Miranda warnings or has invoked the right to counsel and a lawyer is not yet present, is admissible in evidence, as long as the statement was not given in response to police questioning or other conduct by the police likely to produce an incriminating response. (Rhode Island v. Innis {{ussc|446|291|1980}})

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There is also a "public safety" exception to the requirement that Miranda warnings be given before questioning: for example, if the defendant is in possession of information regarding the location of an unattended gun or there are other similar exigent circumstances which require protection of the public, the defendant may be questioned without warning and his responses, though incriminating, will be admissible in evidence. (New York v. Quarles {{ussc|467|649|1984}})

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A number of empirical studies by both supporters and opponents of Miranda have concluded that the giving of Miranda warnings has little effect on whether a suspect agrees to speak to the police without an attorney. However, Miranda's opponents, notably law professor Paul Cassell, argue that letting go 3 or 4% of criminal suspects (who would be prosecuted otherwise but for defective Miranda warnings or waivers) is still too high a price to pay.

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Miranda survived a strong challenge in Dickerson v. United States (2000), where the validity of Congress's overruling of Miranda was tested. At issue was whether the Miranda warnings were actually compelled by the U.S. Constitution, or were rather merely prophylactic measures enacted as a matter of judicial policy.

Related Topics:
2000 - U.S. Constitution

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In Dickerson, the Court held 7-2 that the Miranda warnings were indeed required by the Constitution, speaking through Chief Justice William H. Rehnquist. In dissent, Justice Antonin Scalia argued that the Miranda warnings were not constitutional in nature, citing cases where the Court held the Miranda warnings to be unnecessary.

Related Topics:
William H. Rehnquist - Antonin Scalia

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Dickerson reached the Court under a bizarre set of circumstances. Although the Justice Department under President Clinton had treated Miranda as valid, the Supreme Court was forced to grant certiorari to prevent a circuit split after the 4th Circuit (on its own initiative) took up Professor Cassell's suggestion and ruled that Congress had overruled Miranda with the Crime Control and Safe Streets Act. The Solicitor General refused to defend the constitutionality of the Act, so the Court invited Professor Cassell to argue against the validity of Miranda.

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The Justice Department's treatment of Miranda was not unusual. Most American law enforcement personnel now like Miranda, for one simple reason. After Miranda, it became very difficult for criminal defense attorneys to argue that a confession was not the product of free will, when the defendant's confession was preceded by at least two oral warnings (at arrest and in the interrogation room) and the act of reading and signing a waiver form (which included the warnings in writing).

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Over time, interrogators began to think of clever techniques to honor the "letter" but not the "spirit" of Miranda. In the 2004 case of Missouri v. Seibert, the Supreme Court halted one of the most egregious practices. Missouri police were deliberately withholding Miranda warnings and questioning suspects until they obtained confessions, then giving the warnings, getting waivers, and getting confessions again. Justice Souter wrote for the plurality: "Strategists dedicated to draining the substance out of Miranda cannot accomplish by training instructions what Dickerson held Congress could not do by statute."

Related Topics:
2004 - Missouri v. Seibert

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