Dickerson v. United States

Following is the case brief for Dickerson v. United States, 530 U.S. 428 (2000).

Case Summary of Dickerson v. United States:

  • Petitioner, prior to his criminal trial, moved to suppress a statement he made because he was never given his Miranda warnings.  The District Court granted the motion.
  • The Fourth Circuit Court of Appeals reversed.  The Fourth Circuit held that the statement was admissible based on a federal statute that was passed in order to overrule the Miranda decision.  Thus, the federal statute superseded the Miranda decision.
  • The Supreme Court reversed the Fourth Circuit.  It held that Miranda is a constitutional decision and cannot be superseded by a federal statute.
  • The Court reasoned that the Miranda decision is constitutional in nature because many subsequent cases have applied it to state court matters.  Also, the Court was reluctant to overrule it because the famous Miranda warnings have become so much a part of our national culture.

Dickerson v. United States Case Brief

Statement of the Facts:

The Supreme Court, in Miranda v. Arizona, 384 U.S. 436 (1966), held that a person must be given certain warnings before his statements made during a custodial interrogation would be admissible as evidence against him.  Two years later in 1968, Congress passed 18 U.S.C. 3501 in an attempt to legislatively overrule Miranda.  Section 3501 stated that the admissibility of such statements turns only on whether they were voluntary, which was the standard prior to the Miranda decision.  The Supreme Court and courts throughout the nation, however, continued to use the Miranda standard.

In the present case, Petitioner Dickerson was indicted for a number of robbery-related federal crimes.  Prior to trial, he moved to suppress a statement he made to the FBI.  He argued to the District Court that he was not given his Miranda warnings prior to making the statement.  The District Court agreed with Dickerson and granted his motion to suppress.

Procedural History:

Following the District Court’s suppression of the statement, the Government filed an interlocutory appeal.  The Fourth Circuit Court of Appeals reversed.  The Fourth Circuit held that even though Dickerson was not given his Miranda warnings, the statement was voluntary and therefore admissible in accordance with Section 3501.  The Supreme Court granted certiorari because of the importance of the issue.

Issue and Holding:

Does Congress have the constitutional authority to supersede the Court’s Miranda rule?  No.

Judgment:

The Fourth Circuit Court of Appeals decision is reversed.

Rule of Law or Legal Principle Applied:

The Court’s Miranda decision governs whether a statement made during a custodial interrogation is admissible in both state and federal court, and it cannot be overruled by an Act of Congress.

Reasoning:

  • Miranda is a constitutional decision.

Miranda is a constitutional decision, and Congress may not supersede the Court’s decisions interpreting and applying the Constitution.  The fact that Miranda is a constitutional decision is demonstrated in two primary ways:

First, the rule in Miranda and its companion cases have been applied in state courts, and the Court has done so since Miranda was decided.  The Court’s authority over state courts is limited to enforcing the Constitution, thus it must be a constitutional decision.

Second, the Miranda opinion itself shows that the Court believed it was announcing a constitutional rule.  The Court did invite legislative action in Miranda, but noted that such action should be at least as protective of a suspect’s Fifth Amendment rights as the Miranda rule.  Section 3501 falls short of providing such protection to suspects who are being interrogated while in custody.

  • The Court declines to override Miranda based on stare decisis, and because Miranda is ingrained in our national culture.

The Court is loathe to overrule Miranda based on stare decisis.  There is no special justification suggesting that the Court avoid following the well-established precedent of Miranda.  Indeed, the Court recognized that Miranda has become so embedded in police practice that it has become part of the national culture.

Although the Miranda rule can result in a guilty person going free, the rule is far easier for police to apply routinely and consistently compared to the vague voluntariness standard of Section 3501.

Dissenting Opinion (Scalia):

The Court’s opinion is a judicial overreach.  Now, the Court not only can disregard an Act of Congress when it violates the Constitution but can do so when the Act violates a “constitutional rule” announced by the Court.  That is a frightening and un-democratic power that does not exist.

Significance:

Dickerson v. United States raised Miranda to the level of constitutional necessity, rather than it being merely a prophylactic rule to help enforce the Fifth Amendment.  It is interesting that Chief Justice Rehnquist, a conservative voice on the Court, wrote the opinion.  The most common takeaway from the case is the Court’s statement that the Miranda warnings are so routine in law enforcement that the warnings have become a part of American culture.

Student Resources:

https://supreme.justia.com/cases/federal/us/530/428/case.html

https://www.oyez.org/cases/1999/99-5525

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