Following is the case brief for Rhode Island v. Innis, Supreme Court of the United States, (1980)
Case summary for Rhode Island v. Innis:
- Innis was arrested, read his Miranda rights and subsequently placed in a squad car.
- On the way to the police station, one officer stated how he was worried that one of the children from the handicapped school, which was in close proximity, might find the alleged missing gun and harm themselves or another child.
- In response, Innis explained where the gun was located since he did not want any children to be harmed. Innis later tried to have this statement along with the gun excluded from evidence.
- The Court held that the statement made by the police did not amount to an interrogation under Miranda, as the officers could not have reasonably expected their statements amongst each other to elicit an incriminating response.
Case Brief for Rhode Island v. Innis
Statement of the facts:
Innis was convicted of murder, robbery and kidnapping. When arrested, Innis was unarmed and read his Miranda rights. The arresting officers suspected that a gun was hidden close to where he was apprehended. Innis told the officers that he knew his rights and wanted an attorney. After being placed in the back of a squad car, the officers began discussing their concerns regarding the location of the gun and its proximity to a nearby handicapped school. The officers specifically voiced their fear that a child may find the gun and harm themselves or another child. In response, Innis disclosed the location of the gun to the officers because he did not want any children to get hurt. At trial, the judge held that Innis had properly received his Miranda rights and that the officers addressing their concerns for the children in the presence of Innis was understandable. As a result, the gun and the statement were introduced at trial.
On appeal, the state supreme court reversed the trial court’s decision. The Supreme Court of the United States granted Certiorari.
Rule of Law or Legal Principle Applied:
Interrogation refers to any words or conduct by the police that they should know may reasonably elicit an incriminating response from the suspect.
Issue and Holding:
Under Miranda is a person interrogated when they are in a squad car with an officer who expresses their concerns for the safety of the public? No.
The Court reversed the state supreme court’s judgment.
An interrogation for purposes of Miranda occurs when an officer should reasonably know that their own comments may elicit an incriminating statement by a suspect. When statements are made amongst officers, those statements do not qualify as an interrogation. However, an interrogation is not limited to situations where police are specifically questioning a suspect, because the whole point of the Miranda opinion was centered on the interaction between the police and the suspect in its entirety.
For purposes of Miranda these interactions include line ups, psychological ploys in addition to direct questioning. The Court held that as a result, Miranda applies to a suspect who is subject to questioning as well any procedural equivalent.
Here, the facts do not indicate that the officers actually knew or should have known that Innis would confess to the guns location based on his sensitivity for handicapped children. The record does not reflect that the officers were attempting to conjure a response from Innis or that the officers should have known their remarks made amongst each other would elicit a response.
Concurring or Dissenting opinion:
The Court properly defines “interrogation” but pursuant to the present facts, the only conclusion that can be drawn is that Innis was exposed to an interrogation. This is because any suspect in the defendant’s position would feel obligated to speak when faced with the possibility of an innocent, handicapped child being hurt.
The majority’s ruling is inconsistent with Miranda. This is because it permits officers to make statements designed to elicit responses from a suspect. Officers must avoid phrasing their statements as a question.
This case set the precedent for what constitutes an interrogation for Miranda purposes. The interaction is not limited to just verbal communications between an officer and a suspect. However, when a suspect responds to a police remark that is not reasonably expected to elicit an incriminating response, the statement made by the officer is not automatically an interrogation.