Miranda v. Arizona
384 U.S. 436 (1966)
Constitutional Topic Areas:
Amendments 5, 6, and 14, Appellate Jurisdiction
Case Facts:
On March 13, 1963 Ernesto Miranda was arrested by Phoenix, Arizona police on circumstantial evidence for the crime of a recent kidnaping and rape. Before his interrogation, Miranda was not provided by police his right for an attorney to be present, as well as his right to remain silent and the fact that anything he said could be used against him in court. After two hours of interrogation, Miranda signed a confession stating he was guilty for the kidnaping and rape and that he understood all of his rights afforded to him. At trial, prosecutors used the written confession as evidence against him. Miranda’s court appointed attorney moved to exclude this evidence, as he did not understand his rights at the time. The court allowed the confession and Miranda was convicted of the crime and sentenced to 20-30 years in prision. Miranda appealed, but the appellate court affirmed the lower court’s decision. Miranda then appealed again to the Arizona Supreme Court, who again affirmed the lower courts citing that Miranda did not request an attorney to be present during interrogation, as well as the voluntary nature of the confession. Miranda then appealed to the US Supreme Court via a writ of certiorari
Questions:
1. Does the 5th Amendment’s Due Process Clause apply to self-incrimination during police interrogations?
Holding:
1. Yes
Legal Reasoning: Chief Justice E. Warren (5-4)
1. Under the 5th Amendment’s Self Incrimination Clause, no confessions are admissible in court unless the defendant has been made aware of these specific rights and has officially waived them
2. Specifically, a defendant must be made aware of their right to remain silent, have an attorney be present for questioning and have one appointed to them if they cannot afford one on their own, and that anything said may be used against them in court
3. Further, if the defendant exercises these rights during an interrogation, the interrogation must cease immediately
4. Relying on recently established precedent from Escobedo v. Illinois, any defendant is afforded their 6th Amendment right to have an attorney present for interrogation by police and if this right is not honored, any confession or evidence gathered is inadmissible in court
Concurrence/Dissent: Justice T.C. Clark
1. The majority goes too far, too fast by unnecessarily interpreting the 5th Amendment too strictly, thereby limiting police to do their jobs effectively. Moreover, just because a defendant was not specifically informed of their rights should not mean any confession is inadmissible in court
2. Using the totality of circumstances test developed in Haynes v. Washington, the state should bear the burden of proving that the defendant willingly and intelligently waived their rights afforded in the 5th and 6th Amendments, and that any confessions were willingly and voluntarily given, even if these necessary warnings were not given by interrogating officials
Dissent: Justice J.M. Harlan II
1. The Court is strongly exercising judicial activism in this case, as the Constitution’s text does not specifically make note of any implication to inform defendants of their rights
2. Creating doctrines based on inferences of the Constitution, rather than on its specific text, diminishes the Court’s constitutional legitimacy
Dissent: Justice B.R. White
1. The 5th Amendment’s Self Incrimination Clause only protects defendants from giving self-incriminating testimony only when specifically compelled to do so by interrogating officials. Moreover, defendants who give confessions under normal interrogation proceedings do so willingly, as the process is not inherently coercive
2. The majority’s interpretation of the 5th Amendment will harm the criminal justice process and will lead to guilty criminals to escape justice
Significance:
Miranda established the development of the so-called “Miranda Rights” warning, whereby law enforcement officers are legally obligated to read 5th and 6th Amendment guaranteed rights to arrested persons before interrogation. The warning reads: “You have the right to remain silent. Anything you say can be used against you in court. You have the right to talk to a lawyer for advice before we ask you any questions. You have the right to have a lawyer with you during questioning. If you cannot afford a lawyer, one will be appointed for you before any questioning if you wish. If you decide to answer questions now without a lawyer present, you have the right to stop answering at any time”
Reflection:
The implicitly weak 5-4 ruling in Miranda suggests it could be overturned in the future, however Miranda survived several challenges, namely Dickerson v. US in 2000. In Dickerson, the Court found 7-2 that Miranda Warnings have become an integral part of national culture, as well as that the inherent pressure and coercion of an interrogation are sufficient enough reasons to leave Miranda intact. Overall, Miranda strengthened the power of the federal government
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