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.

The case

Background

In 1963, Ernesto Miranda, an Arizona native with only an elementary school education, was arrested for robbery, kidnapping, and rape. He was interrogated by police and confessed. At trial, prosecutors offered only his confession as evidence. Miranda was convicted of rape and kidnapping and sentenced to 20 to 30 years on both charges. Miranda's lawyer, Alvin Moore, appealed to the Arizona Supreme Court but the charges were upheld.

Related Topics:
1963 - Ernesto Miranda - Arizona - Elementary school - Interrogated - Arizona Supreme Court

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Decision

Chief Justice Warren, a former prosecutor, delivered the opinion of the Court, ruling that due to the coercive nature of custodial interrogation by police (to bolster his point, Warren controversially cited several police training manuals), no confession could be admissible under the Fifth Amendment self-incrimination clause and Sixth Amendment right to an attorney unless a suspect had been made aware of his rights and the suspect had then waived them. Thus, Miranda's conviction was overturned.

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The Supreme Court set down a set of guidelines for custodial interrogations. The ruling stated:

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The person in custody must, prior to interrogation, be clearly informed that he has the right to remain silent, and that anything he says will be used against him in court; he must be clearly informed that he has the right to consult with a lawyer and to have the lawyer with him during interrogation, and that, if he is indigent, a lawyer will be appointed to represent him.

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The Supreme Court also made clear what had to happen if the suspect chose to exercise his rights:

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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 ... If the individual states that he wants an attorney, the interrogation must cease until an attorney is present. At that time, the individual must have an opportunity to confer with the attorney and to have him present during any subsequent questioning.

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Although the ACLU had urged the Supreme Court to require the mandatory presence of a "station-house" lawyer at all police interrogations, Warren refused to go that far, or to even include a suggestion that immediately demanding a lawyer would be in the suspect's best interest. Either measure would make interrogations useless because any competent defense attorney would instruct his client to say nothing to the police.

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However, the dissenting justices thought that the suggested warnings would ultimately lead to such a drastic effect — they apparently believed that once warned, suspects would always demand attorneys and deny the police the ability to seek confessions—and accordingly accused the majority of overreacting to the problem of coercive interrogations.

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In dissent, 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". Harlan closed his remarks by quoting former Justice Robert H. Jackson: "This Court is forever adding new stories to the temples of constitutional law, and the temples have a way of collapsing when one story too many is added".

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Justice White, in his dissent, criticized the Court's new "bright-line rule" for undermining effective law enforcement and marginalizing the rights of society to be free of crime:

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In some unknown number of cases the Court's rule will return a killer, a rapist or other criminal to the streets and to the environment which produced him, to repeat his crime whenever it pleases him. As a consequence, there will not be a gain, but a loss, in human dignity. The real concern is not the unfortunate consequences of this new decision on the criminal law as an abstract, disembodied series of authoritative proscriptions, but the impact on those who rely on the public authority for protection and who without it can only engage in violent self-help with guns, knives and the help of their neighbors similarly inclined. There is, of course, a saving factor: the next victims are uncertain, unnamed and unrepresented in this case.

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Miranda was retried, and this time the police did not use the confession but called witnesses and used other evidence. Miranda was convicted, and served 11 years.

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