Miranda v. Arizona

Following is the case brief for Miranda v. Arizona, United States Supreme Court, (1966)

Case Summary of Miranda v. Arizona:

  • Miranda was taken into custody by police for purposes of interrogation, where he later confessed.
  • Miranda was not informed of his Fifth Amendment right to remain silent or right to have counsel present.
  • Evidence of each confession was used at trial. Miranda was convicted and appealed
  • United States Supreme Court held that a suspect must be informed of their Fifth Amendment rights (right to remain silent and have an attorney present during interrogation) when taken into custody.

Case Brief

Statement of Facts:

Miranda was arrested at his home and brought to the police station for questioning.  He was never informed of his right to remain silent or right to have counsel present. After two hours of interrogation, Miranda made incriminating statements including an oral and signed a written confession. Evidence of the oral confession through police testimony and the written confession were later used against him at trial. As a result, Miranda was found guilty of rape and kidnapping.

Procedural History:

Arizona trial court found Miranda guilty of rape and kidnapping. Upon appeal to the state supreme court, the conviction was affirmed because Miranda did not specifically ask for counsel. Miranda then joined several other defendants and petitioned to the Supreme Court of the United States for review.

Issue(s) and Holding:

Is the Fifth Amendment right against self-incrimination violated when an individual is taken into custody for interrogation purposes without being informed of his constitutional rights to remain silent and have counsel present? Yes.

Judgment:

Chief Justice Warren led the majority in Reversal.

Rule of Law or Legal Principle applied:

When taken into custody, an individual has a right against self-incrimination under the Fifth Amendment, requiring the individual to be informed of his constitutional rights.

Reasoning:

  • The right against self-incrimination applies not only at trial but when a suspect is taken into police custody. Since Miranda was not informed of his rights, his confession was coerced by police in violation of the Fifth Amendment.

Yes. Once subject to custodial interrogation, the Fifth Amendment requires that a suspect is informed of their constitutional rights to: remain silent, have an attorney present, if he cannot afford an attorney one will be appointed to him and that any statement made may later be used against them at trial.

The court took into consideration common police tactics and police instruction manuals and determined that each uncovered an interrogation procedure aimed at attaining confessions through coercive means. For example, many occur when the suspect is isolated and put in unfamiliar or intimidating surroundings.  

The Court held that police are encouraged to use trickery and make the false promises necessary to obtain a confession. Although such methods are not physically coercive, the interrogation process is aimed at putting the suspect in an emotionally vulnerable state so his judgment is impaired. These coercive tactics are a violation of the Fifth Amendment. To ensure that a confession is obtained voluntarily, a suspect must be informed of his constitutional right against self-incrimination in addition to the consequences of a waiver. A waiver of Fifth Amendment rights must be made voluntary, intelligently and knowingly.

A suspect must also be informed that they have a right for counsel to be present. Indigent individuals should receive the same right and will be provided counsel if they cannot afford private representation. Denial of this right also constitutes a violation of the Fifth Amendment, as such presence can prevent improperly coercive police tactics. When a suspect asserts his Fifth Amendment right to an attorney or right to remain silent, the police must cease questioning.

Concurring/Dissenting Opinion(s):

Dissent (Harlan):

Such a holding frustrates the job of law enforcement. The Court’s definition of “voluntariness” is inconsistent with precedent.  The constitution does not prohibit intrusion by the government when probable cause or a warrant is present.

Dissent (White):

The conclusion that spontaneous statements are admissible, while those responsive to police questioning are coercive, conflicts with common sense. No evidence supports that all confessions made during an in-custody interrogation are coerced. If such evidence did exist, nothing supports the conclusion that having counsel present will yield in a less coercive interrogation.

Significance:

This is the landmark case from which we get our “Miranda” warnings.  These warnings serve as a safeguard to protect individual rights, specifically once taken into custody.

Student Resources:

http://www.pbs.org/wnet/supremecourt/rights/landmark_miranda.html
http://caselaw.findlaw.com/us-supreme-court/384/436.html

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