Doyle v. Ohio Case Brief

Why is the case important?

Two individuals were convicted of selling marijuana. During cross examination, the prosecutor asked why they did not tell the police the post-Miranda exculpatory story that they told during trial.

Facts of the case

Question

Whether a state prosecutor may seek to impeach a defendant’s exculpatory story, told for the first time at trial, by cross-examining the defendant about his failure to have told the story after receiving Miranda warnings at the time of his arrest.?

Answer

Use of the defendant’s post-arrest silence in this manner violates due process. The majority observed, silence in the wake of these warnings may be nothing more than the arrestee’s exercise of these Miranda rights. Thus, every post-arrest silence is insolubly ambiguous because of what the State is required to advise the person arrested. Further, while it is true that the Miranda warnings contain no express assurance that silence will carry no penalty, such assurance is implicit to any person who receives the warnings. In such circumstances, it would be fundamentally unfair and a deprivation of due process to allow the arrested person’s silence to be used to impeach an explanation subsequently offered at trial.

Conclusion

The use of the defendant’s post-arrest silence in this manner violates due process.” The majority observed, “[s]ilence in the wake of these warnings may be nothing more than the arrestee’s exercise of these Miranda rights. Thus, every post-arrest silence is insolubly ambiguous because of what the State is required to advise the person arrested.” Further, “while it is true that the Miranda warnings contain no express assurance that silence will carry no penalty, such assurance is implicit to any person who receives the warnings. In such circumstances, it would be fundamentally unfair and a deprivation of due process to allow the arrested person’s silence to be used to impeach an explanation subsequently offered at trial.

  • Case Brief: 1976
  • Petitioner: Doyle
  • Respondent: Ohio
  • Decided by: Burger Court

Citation: 426 US 610 (1976)
Argued: Feb 23, 1976
Decided: Jun 17, 1976