Miranda v. Arizona, 384 U.S.
436
(1966)
Primary Holding
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.
Facts
Ernesto Miranda was arrested in Phoenix due to circumstantial
evidence that he had been involved in a kidnapping and rape. He
confessed to the charges following a lengthy interrogation and signed a
statement that said the confession was made knowingly and voluntarily.
Miranda never was told of his right to remain silent, of his right to have
a lawyer, or of the fact that any of his statements during the
interrogation could be used against him in court. He objected to the
introduction of the written copy of his confession into evidence at trial,
stating that his ignorance of his rights made the confession involuntary.
When the objection was overruled, Miranda was convicted of the
kidnapping and rape at least in part because of the written confession,
and he was sentenced to 20-30 years in prison. An appeal based on
the confession's allegedly involuntary nature was rejected by the
Arizona Supreme Court.
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Attorneys
Alvin Moore (defendant)
Opinions
Majority
Earl Warren (Author)
Hugo Lafayette Black
William Orville Douglas
William Joseph Brennan, Jr.
Abe Fortas
Warren felt that a police interrogation is such an intimidating situation
for most suspects that it triggered the Fifth Amendment protection
against self-incrimination and the Sixth Amendment right to an attorney
unless the suspect waived those rights. The opinion also emphasized
the need for law enforcement to strictly comply with those rights if a
suspect exercises them. Since this decision followed Gideon v.
Wainwright, which held that there was an absolute right to counsel for
indigent criminal defendants, the right to an attorney included the
appointment of a public defender if the suspect was indigent.
Exercising the right to an attorney also expanded that Sixth
Amendment protection to having an attorney during questioning after
arrest and before trial, not a situation that Gideon contemplated. As
part of the foundation for his reasoning, Warren used FBI practices and
rules governing interrogations of military service members suspected
of crimes.
Concurrence/Dissent In Part
:
Tom C. Clark (Author)
Clark was uneasy about what appeared to be a sweeping rule that the
majority had created. He advocated using a totality of the
circumstances standard from the decision in Haynes v. Washington.
This would permit a court to make a case-by-case evaluation while
placing the burden on the state to show that the Miranda rights were
waived or that the confession was voluntary under the specific
circumstances.
Dissent
John Marshall Harlan II (Author)
Harlan felt that the majority opinion was an example of impermissible
judicial activism, since it lacked support in the text of the Constitution
or other law. He argued that creating entire doctrines through inference
reduced the legitimacy of constitutional law overall.
Dissent
Byron Raymond White (Author)
Echoing Harlan, White noted that the majority not only had no textual
foundation in the Constitution for its opinion but also lacked any Court
precedents. He even researched English common law to confirm that it
contained no support for Warren. White ominously observed that the
majority's rule, if diligently applied, could lead to serious criminals
escaping justice.
Case Commentary
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.
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