Dickerson v. United States

PETITIONER: Dickerson
RESPONDENT: United States
LOCATION: FBI Field Office

DOCKET NO.: 99-5525
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 530 US 428 (2000)
ARGUED: Apr 19, 2000
DECIDED: Jun 26, 2000

ADVOCATES:
James W. Hundley - Argued the cause for the petitioner
Paul G. Cassell - As amicus curiae, supporting the judgment below
Seth P. Waxman - Argued the cause for the respondent

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."

Question

May Congress legislatively overrule Miranda v. Arizona and its warnings that govern the admissibility of statements made during custodial interrogation?

Media for Dickerson v. United States

Audio Transcription for Oral Argument - April 19, 2000 in Dickerson v. United States

Audio Transcription for Opinion Announcement - June 26, 2000 in Dickerson v. United States

William H. Rehnquist:

I have the opinion of the Court to announce in No. 99-5525, Dickerson against United States.

You have the right to remain silent; anything you say can be used against you in the court of law.

You have the right to the presence of an attorney.

If you cannot afford an attorney, one will be provided for you prior to any questioning.

If you so desire.

These four warnings that accord to police stations and on television screens.

In the 34 years since we decided the case of Miranda versus Arizona.

In that opinion we held that any statement a suspect makes while in police custody is not admissible in the prosecution’s case in chief, unless the statement was preceded by these warnings.

The present case Dickerson addresses whether Miranda has been superseded by an Act of Congress passed in 1968.

We hold that Miranda is a constitutional decision that may not be overruled by Congress and we decline to overrule Miranda ourselves.

We therefore hold that Miranda and its progeny continue to govern the admissibility of statements made during custodial interrogation.

Petitioner Charles Dickerson was indicted for bank robbery and related federal crimes.

Before trial he moved to suppress an incriminatory statement he made at an FBI Field Office on the ground that he had not received Miranda warnings.

The District Court granted his motion to suppress.

On appeal, the Court of Appeals for the Fourth Circuit agreed that his statement was taken in violation of Miranda, but concluded that the statement should nevertheless be admitted because Miranda had been superseded by 18 U.S.C. Section 3501, a statute passed by Congress in 1968.

Section 3501 displays Miranda’s specific warnings requirement with a test that looks to whether given the totality of the circumstances surrounding a suspect's statement.

The statement was voluntarily given.

Because of the importance of the issues raised by the Court of Appeals decision we granted certiorari.

It’s well-established that the Constitution proscribes the admission of any confession that is obtained involuntarily.

We have never abandoned that requirement, but since Miranda, in 1966, we have also enforced the rule that any custodial statement must be preceded by specific warnings to be admissible in the prosecutions case in chief.

Because 3501, the Act of Congress seeks to abandon Miranda’s warning requirement and return to voluntariness, this case turns on whether Congress has constitutional authority to supersede Miranda.

The law in this area is clear.

Congress has authority to supersede non constitutional judicially created rules of evidence and procedure, but Congress may not legislatively overrule our decisions interpreting and applying the Constitution.

The dispositive question therefore is whether the Miranda court announced a constitutional rule or merely exercised its supervisory authority to regulate evidence in the absence of Congressional direction.

For a number of reasons we think it clear that Miranda’s rule is constitutionally based.

First, both Miranda and two of its companion cases applied the new warning requirements to proceedings in State Courts.

We do not have a supervisory power over the courts of the State and may only require those tribunals to comply with the dictates of the Federal Constitution.

Second, the Miranda opinion itself is replete with statements indicating that the Court thought it was announcing a constitutional rule.

Third, while the Miranda Court invited legislative action to protect the constitutional right against self-incrimination, it specified that such legislation must be effective in apprising the accused of their right of silence.

The fact that our post Miranda cases have made exceptions from its rule does not demonstrate that Miranda was not a constitutional decision.