Miranda v. Arizona

Why is the case important?

Miranda v. Arizona Brief The central theme of this case was Miranda warnings and the protections against self-incrimination included in the Fifth Amendment.

Facts

The Supreme Court of the United States (“Supreme Court”) consolidated four separate cases with issues regarding the admissibility of evidence obtained during police interrogations.
The first Defendant, Ernesto Miranda (“Mr. Miranda”), was arrested for kidnapping and rape. Mr. Miranda was an immigrant, and although the officers did not notify Mr. Miranda of his rights, he signed a confession after two hours of investigation. The signed statement included a statement that Mr. Miranda was aware of his rights.

The second Defendant, Michael Vignera (“Mr. Vignera”), was arrested for robbery. Mr. Vignera orally admitted to the robbery to the first officer after the arrest, and he was held in detention for eight hours before he made an admission to an assistant district attorney. There was no evidence that he was notified of his Fifth Amendment constitutional rights.

The third Defendant, Carl Calvin Westover (“Mr. Westover”), was arrested for two robberies. Mr. Westover was questioned over fourteen hours by local police, and then was handed to Federal Bureau of Investigation (“FBI”) agents, who were able to get signed confessions from Mr. Westover. The authorities did not notify Mr. Westover of his Fifth Amendment constitutional rights.

The fourth Defendant, Roy Allen Stewart (“Mr. Stewart”), was arrested, along with members of his family (although there was no evidence of any wrongdoing by his family) for a series of purse snatches. There was no evidence that Mr. Stewart was notified of his rights. After nine interrogations, Mr. Stewart admitted to the crimes.

Key Players

1 Appellant: Ernesto Miranda, who was questioned about and confessed to a crime in police custody without being informed of his right to have an attorney present while communicating with police. Appellee: The State of Arizona and, specifically, the Phoenix Police Department, who detained, questioned, and elicited a confession from Miranda without warning him that he had a right to have an attorney present during questioning.

Question

Does the Fifth Amendment’s protection against self-incrimination extend to the police interrogation of a suspect?

Conclusion

The Fifth Amendment requires that law enforcement officials advise suspects of their right to remain silent and to obtain an attorney during interrogations while in police custody. Chief Justice Earl Warren delivered the opinion of the 5-4 majority, concluding that defendant’s interrogation violated the Fifth Amendment. To protect the privilege, the Court reasoned, procedural safeguards were required. A defendant was required to be warned before questioning that he had the right to remain silent, and that anything he said can be used against him in a court of law. A defendant was required to be told that he had the right to an attorney, and if he could not afford an attorney, one was to be appointed for him prior to any questioning if he so desired. After these warnings were given, a defendant could knowingly and intelligently waive these rights and agree to answer questions or make a statement. Evidence obtained as a result of interrogation was not to be used against a defendant at trial unless the prosecution demonstrated the warnings were given, and knowingly and intelligently waived. Justice Tom C. Clark wrote a dissenting opinion in which he argued that the majority’s opinion created an unnecessarily strict interpretation of the Fifth Amendment that curtails the ability of the police to effectively execute their duties. He wrote that the state should have the burden to prove that the suspect was aware of his rights during the interrogation, but that statements resulting from interrogation should not be automatically excluded if the suspect was not explicitly informed of his rights. In his separate dissenting opinion, Justice John M. Harlan wrote that the judicial precedent and legislative history surrounding the Fifth Amendment does not support the view that the Fifth Amendment prohibits all pressure on the suspect. He also argued that there was no legal precedent to support the requirement to specifically inform suspects of their rights. Justices Potter Stewart and Byron R. White joined in the dissent. Justice White wrote a separate dissent in which he argued that the Fifth Amendment only protects defendants from giving self-incriminating testimony if explicitly compelled to do so. He argued that custodial interrogation was not inherently coercive and did not require such a broad interpretation of the protections of the Fifth Amendment. Such an interpretation harms the criminal process by destroying the credibility of confessions. Justices Harlan and Stewart joined in the dissenting opinion.

What was the effect of the supreme court case Miranda v. Arizona?

Discussion

The majority notes that once an individual chooses to remain silent or asks to first see an attorney, any interrogation should cease. Further, the individual has the right to stop the interrogation at any time, and the government will not be allowed to argue for an exception to the notification rule.
Miranda v. Arizona Summary The Supreme Court ruled in favor of a man convicted on The basis of a confession that was elicited during The course of Arizona police interrogations which were conducted without warnings of The right to an attorney—warnings which are required to be provided to ensure preservation of The Fifth Amendment’s “privilege against self-incrimination”.

Advocates:
John J. Flynn for the petitioner, 759, Victor M. Earle, III for the petitioner, 760, F. Conger Fawcett for the petitioner, 761, Gordon Ringer for the petitioner, 584, Gary K. Nelson for the respondent, 759, William I. Siegel for the respondent, 760, Thurgood Marshall Solicitor General, for the United States, 761, William A. Norris for the respondent, 584, Telford Taylor for the State of New York as amicus curiae in all cases by special leave of the Court, Duane R. Nedrud for the National District Attorneys’ Association, as amicus curiae
Location:
Phoenix, Arizona
Respondent:
Arizona
Petitioner:
Miranda
Warren Court
Citation:
384 US 436 (1966)
Argued:
Feb 28 – 2, 1966
Decided:
Jun 13, 1966