384 U.S. 436 (1966) |
SCOTUS decided 1966-06-13
Under the Fifth Amendment, any statements that a defendant in custody makes during an interrogation are admissible as evidence at a criminal trial only if law enforcement told the defendant of the right to remain silent and the right to speak with an attorney before the interrogation started, and the rights were either exercised or waived in a knowing, voluntary, and intelligent manner.Result: Mixed
From Justia: The decision was widely attacked at the time for giving criminals extra ways to unfairly escape prosecution. Congress attempted to override it by introducing a law that imposed the totality of the circumstances test supported by Clark, but federal prosecutors did not actually use that law to justify introducing evidence. However, later decisions have restricted some of Miranda’s applications, for example by clarifying that the suspect must clearly and affirmatively assert any of these rights upon receiving the warnings in order to validly exercise them. Courts also have crafted a distinction between confessions and spontaneous statements by defendants, which may be admissible at trial even if Miranda warnings have not been provided, and limits have been placed on the meaning of “custody,” which is the only situation in which the warnings apply. On the other hand, courts have held that waiving Miranda rights is effective only if it is voluntary, knowing, and intelligent, providing defense attorneys with grounds on which to challenge evidence introduced based on waivers.
Ironically, while the case had sweeping effects on the American criminal justice system, it had very little impact on Miranda’s own situation. He was retried for the crimes with the use of other evidence and again sentenced to 20-30 years, although he was released five years later on parole. A minor local celebrity, he autographed the “Miranda cards” that police officers in Phoenix (as in many other cities across the country) used to verify that they had provided proper warnings to suspects. Miranda was eventually killed in an incident that police never resolved, due in part to a suspect exercising his Miranda right to silence.
Law type: Criminal
Topic(s): Right to counsel: Criminal
State of origin: AZ
John J. Flynn argued the cause for petitioner in No.759. With him on the brief was John P. Frank. Victor M. Earle III argued the cause and filed a brief for petitioner in No. 760. F. Conger Fawcett argued the cause and filed a brief for petitioner in No. 761. Gordon Ringer, Deputy Attorney General of California, argued the cause for petitioner in No. 584. With him on the briefs were Thomas C. Lynch, Attorney General, and William E. James, Assistant Attorney General.
Others involved: Anthony G. Amsterdai, Paul J. Mishkin, Raymond L.Bradley, Peter Hearn and Melvin L. Wulf filed a brief for the American Civil Liberties Union, as amicus curiae, in all cases.
Last modified: 2020-05-29 07:15
Case internal grade: A | Case internal status: OK |
Case internal status notes:
Lists: Important cases
For more info: Findlaw
CASE DETAILS(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)
In each of these cases, the defendant, while in police custody, was questioned by police officers, detectives, or a prosecuting attorney in a room in which he was cut off from the outside world. None of the defendants was given a full and effective warning of his rights at the outset of the interrogation process. In all four cases, the questioning elicited oral admissions, and, in three of them, signed statements as well, which were admitted at their trials. All defendants were convicted, and all convictions, except in No. 584, were affirmed on appeal.
1. The prosecution may not use statements, whether exculpatory or inculpatory, stemming from 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, unless it demonstrates the use of procedural safeguards effective to secure the Fifth Amendment’s privilege against self-incrimination. Pp. 444-491.
(a) The atmosphere and environment of incommunicado interrogation as it exists today is inherently intimidating, and works to undermine the privilege against self-incrimination. Unless adequate preventive measures are taken to dispel the compulsion inherent in custodial surroundings, no statement obtained from the defendant can truly be the product of his free choice. Pp. 445-458.
(b) The privilege against self-incrimination, which has had a long and expansive historical development, is the essential mainstay of our adversary system, and guarantees to the individual the “right to remain silent unless he chooses to speak in the unfettered exercise of his own will,” during a period of custodial interrogation
as well as in the courts or during the course of other official investigations. Pp. 458-465.
(c) The decision in Escobedo v. Illinois, 378 U. S. 478, stressed the need for protective devices to make the process of police interrogation conform to the dictates of the privilege. Pp. 465-466.
(d) In the absence of other effective measures, the following procedures to safeguard the Fifth Amendment privilege must be observed: 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. Pp. 467-473.
(e) If the individual indicates, prior to or during questioning, that he wishes to remain silent, the interrogation must cease; if he states that he wants an attorney, the questioning must cease until an attorney is present. Pp. 473-474.
(f) Where an interrogation is conducted without the presence of an attorney and a statement is taken, a heavy burden rests on the Government to demonstrate that the defendant knowingly and intelligently waived his right to counsel. P. 475.
(g) Where the individual answers some questions during in-custody interrogation, he has not waived his privilege, and may invoke his right to remain silent thereafter. Pp. 475-476.
(h) The warnings required and the waiver needed are, in the absence of a fully effective equivalent, prerequisites to the admissibility of any statement, inculpatory or exculpatory, made by a defendant. Pp. 476-477.
2. The limitations on the interrogation process required for the protection of the individual’s constitutional rights should not cause an undue interference with a proper system of law enforcement, as demonstrated by the procedures of the FBI and the safeguards afforded in other jurisdictions. Pp. 479-491.
3. In each of these cases, the statements were obtained under circumstances that did not meet constitutional standards for protection of the privilege against self-incrimination. Pp. 491-499.
98 Ariz. 18, 401 P.2d 721; 15 N.Y.2d 970, 207 N.E.2d 527; 16 N.Y.2d 614, 209 N.E.2d 110; 342 F.2d 684, reversed; 62 Cal. 2d 571, 400 P.2d 97, affirmed.