Dickerson v. United States Case Brief

Facts of the case

During questioning about a robbery he was connected to, Charles Dickerson made statements to authorities admitting that he was the getaway driver in a series of bank robberies. Dickerson was then placed under arrest. The timing of his statement is disputed. The FBI and local detectives testified that Dickerson was advised of his Miranda rights, established in Miranda v. Arizona , and waived them before he made his statement. Dickerson said he was not read his Miranda warnings until after he gave his statement. After his indictment for bank robbery, Dickerson filed a motion to suppress the statement that he made on the ground that he had not received Miranda warnings before being interrogated. The government argued that even if the Miranda warnings were not read, the statement was voluntary and therefore admissible under 18 USC Section 3501, which provides that a confession shall be admissible in evidence if it is voluntarily given.The District Court granted Dickerson’s motion, finding that he had not been read his Miranda rights or signed a waiver until after he made his statement, but the court did not address section 3501. In reversing, the Court of Appeals acknowledged that Dickerson had not received Miranda warnings, but held that section 3501 was satisfied because his statement was voluntary. The court held that Congress enacted section 3501 with the express purpose of legislatively overruling Miranda and restoring voluntariness as the test for admitting confessions in federal court.

Why is the case important?

The petitioner, Charles Thomas Dickerson (the “petitioner”), made a statement regarding a bank robbery to the Federal Bureau of Investigations (“FBI”) without receiving his Miranda rights. A federal law was in place that allowed the admission of statements if they were voluntarily made.

Question

The issue is whether Congress can overrule the Fourth and Fourteenth Amendment constitutional protections outlined in Miranda.

ANSWER

The protections outlined in Miranda, are protections mandated by the Constitution. Therefore Congress, through a federal law, can not overrule Miranda. The United States Supreme Court is not willing to overrule Miranda, and therefore the statements should be suppressed.

CONCLUSION

On appeal, the court reversed, finding that Miranda was a constitutional decision of the court, and therefore could not be in effect overruled by an Act of Congress. Further, following the principles of stare decisis, the court declined to overrule Miranda itself. The court held that Miranda and its progeny governed the admissibility of statements made during custodial interrogation in both state and federal courts.

  • Advocates: Paul G. Cassell As amicus curiae, supporting the judgment below James W. Hundley Argued the cause for the petitioner Seth P. Waxman Argued the cause for the respondent
  • Petitioner: Dickerson
  • Respondent: United States
  • DECIDED BY:Rehnquist Court
  • Location: FBI Field Office
Citation: 530 US 428 (2000)
Argued: Apr 19, 2000
Decided: Jun 26, 2000
Dickerson v. United States Case Brief