Berkemer v. McCarty

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Following is the case brief for Berkemer v. McCarty, 468 U.S. 420 (1984).

Case Summary of Berkemer v. McCarty:

  • Respondent McCarty was stopped by police for driving while intoxicated.  McCarty responded to police questions during the traffic stop and after he was put in jail.  Police never read McCarty his Miranda rights.
  • The trial court denied McCarty’s motion to exclude his statements to police.  McCarty was found guilty of driving while intoxicated.  McCarty appealed his case in both State and Federal court, claiming his Fifth Amendment rights were violated.
  • The U.S. Supreme Court agreed to hear the case.  It determined that Miranda rights should be administered whenever a person is subjected to custodial interrogation, regardless of the seriousness of the charge.

Berkemer v. McCarty Case Brief

Statement of the Facts:

In 1980, Trooper Williams of the Ohio Highway Patrol noticed a car driving erratically.  Williams stopped the car and asked the driver, respondent McCarty, to step out of the car.  Williams noticed that McCarty was having difficulty standing.  Williams asked McCarty to perform a field sobriety test, which McCarty failed.  Williams then asked McCarty if he had used intoxicants, to which McCarty replied that he drank two beers and smoked marijuana shortly before being stopped.

Williams formally put McCarty under arrest and brought him to the county jail.  At the jail, a test of McCarty’s blood-alcohol level showed no signs of alcohol in his system.  Upon further questioning by Williams, McCarty said he had been drinking and was “barely” intoxicated at that point. McCarty indicated that the marijuana he smoked was not treated with any other drug.  At no point did Williams recite the Miranda warnings to McCarty.

Procedural History:

  • McCarty was charged with driving while intoxicated, a misdemeanor.  McCarty moved to have his statements suppressed because they were in violation of Miranda.  The trial court denied the motion and subsequently found him guilty.
  • The State appeals court affirmed McCarty’s conviction, noting that Miranda did not apply to misdemeanors.  The Ohio Supreme Court dismissed McCarty’s appeal.
  • McCarty then filed a habeas petition before the Federal District Court.  That court dismissed the petition, holding that Miranda did not apply for traffic offenses.
  • The Sixth Circuit Court of Appeals reversed, holding that Miranda applies regardless of whether the offense was a felony or misdemeanor.
  • The U.S. Supreme Court granted certiorari to resolve confusion between the Federal and State courts.

Issues and Holdings:

  1. Does the Miranda rule apply to a person who was subjected to custodial interrogation related to a misdemeanor traffic offense?  Yes.
  2. Does roadside questioning of a motorist after a traffic stop amount to custodial interrogation for purposes of Miranda?  No.

Judgment:

The Sixth Circuit Court of Appeals decision is affirmed.

Rule of Law or Legal Principle Applied:

  1. Miranda is required anytime a person is subjected to custodial interrogation, regardless of whether it is in connection with a felony or minor traffic offense.
  2. Questioning of a motorist during a routine traffic stop is not a custodial interrogation for the purposes of Miranda.

Reasoning:

First, whenever people are subjected to the coercive atmosphere of a custodial interrogation, they should be made aware of their constitutional rights.  That conclusion does not hinge upon whether a person is, or is about to be, charged with a felony or misdemeanor.  Indeed, at the time of an interrogation, police often do not know how severe the charge will be.  Creating a Miranda exception for misdemeanors would thereby create confusion in law enforcement.  In sum, the simplicity and clarity of the Miranda rule would be undermined if there was an exception for cases involving misdemeanors.  Therefore, McCarty’s statements at the jail, when he was clearly subjected to custodial interrogation, are inadmissible.

Second, the circumstances of an ordinary traffic stop do not create a situation where a person would believe he or she is “in custody.”  Traffic stops are relatively short in duration and occur in public.  Thus, such a stop lacks the type of police-dominated atmosphere that is typical of someone who is “in custody.”  Based on the facts in this case, McCarty only reasonably believed that he was not free to leave, and therefore “in custody,” when he was formally arrested and not before.

Significance:

Before Berkemer v. McCarty, some courts only required Miranda rights be read for those defendants charged with serious offenses.  This case is significant because it made clear that the Miranda rule applies to anyone in custodial interrogation, regardless of the seriousness of the offense.

Student Resources:

https://supreme.justia.com/cases/federal/us/468/420/case.html

https://www.oyez.org/cases/1983/83-710