Rhode Island v. Innis Case Brief

Facts of the case

After a picture identification by the victim of a robbery, Thomas J. Innis was arrested by police in Providence, Rhode Island. Innis was unarmed when arrested. Innis was advised of his Miranda rights and subsequently requested to speak with a lawyer. While escorting Innis to the station in a police car, three officers began discussing the shotgun involved in the robbery. One of the officers commented that there was a school for handicapped children in the area and that if one of the students found the weapon he might injure himself. Innis then interrupted and told the officers to turn the car around so he could show them where the gun was located.

Why is the case important?

The respondent, Thomas Innis (the “respondent”), was arrested, read his Miranda rights, and put into the backseat of a patrol car. The police discussed that the gun used for the crime might be found by a child, and the respondent disclosed the location of the weapon to avoid an accident.


The issue is whether the conversation between the officers in front of the respondent constituted an interrogation as defined in Miranda v. Arizona?


The conversation was not an interrogation, and therefore the respondent’s rights under the Fifth Amendment of the United States Constitution (“Constitution”) were not violated. Interrogations should not be so broadly defined to include such a wide range of conduct by officers post-arrest, but rather should only include conduct that police should know would illicit a response.


The Court held that the term interrogationunder Miranda referred not only to express questioning, but also to any words or actions on the part of the police that the police should know were reasonably likely to elicit an incriminating response from a suspect. The Court held that Innis was not interrogated within the meaning of Miranda when the police officers voiced safety concerns about children finding the weapon from the crime and Innis interrupted them to say he would show them where the gun was located.

  • Advocates: John A. MacFadyen, III Argued the cause for the respondent Dennis J. Roberts, II Argued the cause for the petitioner
  • Petitioner: Rhode Island
  • Respondent: Innis
  • DECIDED BY:Burger Court
  • Location: Police Car
Citation: 446 US 291 (1980)
Argued: Oct 30, 1979
Decided: May 12, 1980
Rhode Island v. Innis Case Brief