Miranda v. Arizona

Miranda v. Arizona 1966

Miranda v. Arizona is one of three landmark Supreme Court cases in which the Supreme Court transformed the criminal justice system. The Supreme Court established that police had to inform a criminal suspect of his rights as given by Escobedo v. Illinois and Gideon v. Wainwright. It forces police officers to explain that suspects have the right to remain silent, and that anything they say can be used against them.

See Also:Escobedo v. Illinois (1963), Gideon v. Wainwright (1964).

U.S. Supreme Court

MIRANDA v. ARIZONA, 384 U.S. 436 (1966)*

MIRANDA v. ARIZONA.
CERTIORARI TO THE SUPREME COURT OF ARIZONA.
Argued February 28 - March 1, 1966.
Decided June 13, 1966.

Together with No. 760, Vignera v. New York, on certiorari to the Court of Appeals of New York and No. 761, Westover v. United States, on certiorari to the United States Court of Appeals for the Ninth Circuit, both argued February 28 - March 1, 1966; and No. 584, California v. Stewart, on certiorari to the Supreme Court of California, argued February 28 - March 2, 1966.

In each of these cases the defendant while in police custody was questioned by police officers, detectives, or a prosecuting attorney in a room in which he was cut off from the outside world. None of the defendants was given a full and effective warning of his rights at the outset of the interrogation process. In all four cases the questioning elicited oral admissions, and in three of them signed statements as well, which were admitted at their trials. All defendants were convicted and all convictions, except in No. 584, were affirmed on appeal. Held:

1. The prosecution may not use statements, whether exculpatory or inculpatory, stemming from questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way, unless it demonstrates the use of procedural safeguards effective to secure the Fifth Amendment's privilege against self-incrimination. Pp. 444-491
(a) The atmosphere and environment of incommunicado interrogation as it exists today is inherently intimidating and works to undermine the privilege against self-incrimination. Unless adequate preventive measures are taken to dispel the compulsion inherent in custodial surroundings, no statement obtained from the defendant can truly be the product of his free choice. Pp. 445-458.
(b) The privilege against self-incrimination, which has had a long and expansive historical development, is the essential mainstay of our adversary system and guarantees to the individual the "right to remain silent unless he chooses to speak in the unfettered exercise of his own will," during a period of custodial interrogation 384 U.S. 436, 437)* as well as in the courts or during the course of other official investigations. Pp. 458-465.
(c) The decision in Escobedo v. Illinois, 378 U.S. 478*, stressed the need for protective devices to make the process of police interrogation conform to the dictates of the privilege. Pp. 465-466.
(d) In the absence of other effective measures the following procedures to safeguard the Fifth Amendment privilege must be observed: The person in custody must, prior to interrogation, be clearly informed that he has the right to remain silent, and that anything he says will be used against him in court; he must be clearly informed that he has the right to consult with a lawyer and to have the lawyer with him during interrogation, and that, if he is indigent, a lawyer will be appointed to represent him. Pp. 467-473.
(e) If the individual indicates, prior to or during questioning, that he wishes to remain silent, the interrogation must cease; if he states that he wants an attorney, the questioning must cease until an attorney is present. Pp. 473-474.
(f) Where an interrogation is conducted without the presence of an attorney and a statement is taken, a heavy burden rests on the Government to demonstrate that the defendant knowingly and intelligently waived his right to counsel. P. 475.
(g) Where the individual answers some questions during incustody interrogation he has not waived his privilege and may invoke his right to remain silent thereafter. Pp. 475-476.
(h) The warnings required and the waiver needed are, in the absence of a fully effective equivalent, prerequisites to the admissibility of any statement, inculpatory or exculpatory, made by a defendant. Pp. 476-477.

2. The limitations on the interrogation process required for the protection of the individual's constitutional rights should not cause an undue interference with a proper system of law enforcement, as demonstrated by the procedures of the FBI and the safeguards afforded in other jurisdictions. Pp. 479-491.

3. In each of these cases the statements were obtained under circumstances that did not meet constitutional standards for protection of the privilege against self-incrimination. Pp. 491-499.

98 Ariz. 18, 401 P.2d 721; 15 N. Y. 2d 970, 207 N. E. 2d 527; 16 N. Y. 2d 614, 209 N. E. 2d 110; 342 F.2d 684, reversed; 62 Cal. 2d 571, 400 P.2d 97, affirmed.*

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See Also: Landmark Case, Civil Rights Rulings (Circa 1960's)
* Click here to understand what those numbers mean

Miranda v. Arizona (1966) is one of the most famous and most controversial decisions of the United States Supreme Court. In 1963, a young woman from Arizona was driven into the desert and was raped. The police convicted and arrested Miranda. Miranda was interrogated for several hours without understanding his constitutional rights, including the benefit of counsel. The only exhibit at the state trial was his confession. Miranda then took this to the Supreme Court, challenging this on the grounds of the Fifth Amendment.

The court presented one major question: Does the police practice of interrogating individuals without notifying them of their right to counsel and their protection against self-incrimination violate the Fifth Amendment? The court answered, yes, it does violate the Fifth Amendment. So, in this controversial decision (5-4), the Supreme Court reversed Miranda's conviction.

The Court reasoned that the prosecutors could not use statements of defendants which came from interrogation, unless they demonstrated the use of procedural safeguards "effective to secure the privilege against self-incrimination." In addition, the Supreme Court stated that "the modern practice of in-custody interrogation is psychologically rather than physically oriented" and that "the blood of the accused is not the only hallmark of an unconstitutional inquisition." The Court then required the usage of police warnings to suspects, which warn them that they have the right to remain silent, the right to have counsel present during interrogations, and other things. This Due Process guarantee requires that a suspect "must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires. Opportunity to exercise these rights must be afforded to him throughout the interrogation." Miranda was tried again, and was then found guilty.

Many consequences stemmed from this controversial decision. First of all, suspects must be read thier Miranda rights, which wasn't a requirement before. Suspects of crimes, now will have a fair chance of defending themselves, and will be aware of their constitutional and due process rights when being arrested or being convicted.

Sources:http://oyez.nwu.edu/cases/cases.cgi and notes from Government class.