Miranda v.
Arizona
384 U.S. 436
(1966)
CHARACTER OF ACTION: After being convicted by the Arizona supreme court for
kidnapping and rape. Miranda saw a review of his case by appealing to the united states supreme
court on a writ of certiorari. The Court decided to hear that case in conjunction with three similar
cases named Vignera v. New York, Westover v. the United States, and California v. Stewart, all
of which have similar circumstances in the sense that it involved self-incrimination in police
interrogation.
FACTS:
On March 3, 1963, an 18-year-old girl was kidnapped and raped in the Phoenix area. On March
13, ten days later, petitioner Miranda was arrested and taken to the police station. Miranda was
23 years old. Two police officers interrogated him there. Miranda was not informed of his right
to an attorney present; the officers agreed at trial. When the police left the interview area,
Miranda signed an oral statement. The bolded paragraph at the top of the statement stated that
the guilty plea was made deliberately and there was no guarantee of coercion or protection.
During his jury trial, the written statement was entered into evidence against the opposition of
defense attorneys, and the officers testified to Miranda's earlier oral statements during the
questioning. Miranda was convicted of kidnapping and robbery. He was sentenced to 20 to 30
years in prison in each of the charges and served his sentence simultaneously.
.
ISSUE:
Is the statement obtained from the defendant while in police custody without having them given
his/her Fifth Amendment Rights are admissible in the Court of law?
No.
DECISION: (5-4)
Miranda v. Arizona --- Reversed.
Vignera v. New York --- Reversed.
Westover v. the United States ---Reversed.
California v. Stewart --- Affirmed.
MAJORITY OPINION
A. Statements made during detention and interrogation are inadmissible at trial unless such
signatures are provided during the interrogation to remind people of their freedom of silence and
representation.
(i) Custody inquiries occur when law enforcement officials question people arrested and detained
or whose freedom of movement is severely restricted.
(ii) Interrogation in a detention facility may be arbitrary. Isolating criminals from the outside
world provides a good atmosphere for coercion. Self-incrimination has a long history of being
established in court cases.
(iii) In a locked-in, aggressive environment, police officers can take advantage of personal
weaknesses at the expense of personal freedom. The case Escobedo v. Illinois established the
need for the protected devices to make police interrogation less intimidating.
(iv) four things that the fifth amendment gives us
a. You have the right to remain silent.
b. Anything you say can and will be used against you in a court of law.
c. You have the right to an attorney.
d. If you cannot afford an attorney, one will be provided for you.
(v) Before going to jail, prisoners must be informed of their right to remain silent, and it can be
said that what they have said can be used as proof of guilt if the person prior to questioning says
that he/she wants to remain silent. You cannot move forward with the interrogation. If they say,
they want an attorney. You cannot move forward. You have to seize the investigation until the
attorney present.
(vi) If the person wants to proceed with the interrogation and waive their right to an attorney.
The government has the burden to prove that the defendant knowingly and intelligently waives
their right to have an attorney present.
(vii) If you answered some questions and you feel they get too far, and you feel like you want to
invoke your fifth amendment right. Law enforcement cannot go forward with the investigation.
(viii) Anything you say can and will be used against you in a court of law. These warnings have
to be given knowingly, willingly, and intelligently.
B. The limitation on the interrogation process. For example, if you decide you want to cancel the
interrogation. Those limitations should not interfere with the investigation. The government has
to be very careful not to violate someone is right of the fifth amendment.
C. The four men's claims were inadmissible because they were not aware of their rights.
Miranda, Vignera, and Westover's sentences are overturned, and the California Supreme Court's
decision to overturn Stewart's sentence is upheld.
DISSENTING OPINION:-
The Court's decision redefines voluntariness in a manner that
contradicts tradition and precedent. Although detention is painful, the constitution does not
preclude the government from intruding if the probable cause or a warrant is present. The
procedures of the majority stop any confession. And if the Fifth Amendment referred during
pretrial detention interrogations, it would not endorse the majority's rigorous methods.
Legislative changes may result in safer ways and are supported by observational evidence about
the impact of the proposed procedure on law enforcement practices. They also argued that the
fifth amendment and the fourteen-amendment due process clause are better equipped and quicker
to adjusting issues regarding force confession.
DISSENTING OPINION
The Fifth Amendment jurisprudence supports the majority's
procedures. Though the Court is often called upon to create a new law, there is little reasonable
reason to believe that interrogations in custody are intrinsically manipulative or that the
majority's protocols will make the answers voluntary. Furthermore, the majority's procedures
could undermine criminal law enforcement.
DISSENTING OPINION
Justice Tom Clark ("J. Clark") proposed that the Fifth and Fourteenth
Amendments' Due Process Clauses must extend to interrogations. There is insufficient evidence
to support the majority's conclusion that a new rule is needed. He also argued that there was no
evidence to prove that any of these court confessions were voluntary.
COMMENT: Miranda v. Arizona was a landmark Supreme Court decision that holds that a
suspect's statements to police are inadmissible in Court until the defendant is told of their right to
an attorney present during the interrogation and everything, they say will be used against them.
In his paper, legal scholar Jonathan L. wrote about the problems of invoking and denying
Miranda's right to remain quiet. He argues that relying on the Berghuis ruling, police officers
cannot seek a waiver of a defendant's right to stay silent when engaging in questioning.
In his article, the author Kenneth wrote that in an interview, he/she have the right to counsel
under the Fifth Amendment. The Court separated interrogative detention from the detention of
the general prison system. It ruled that unless a lawyer is obtained, law enforcement officials
shall not detain prisoners in pretrial detention who have previously invoked their Fifth
Amendment rights.
PRINCIPLE OF THE CASE:
a. You have the right to remain silent.
b. Anything you say can and will be used against you in a court of law.
c. You have the right to an attorney.
d. If you cannot afford an attorney, one will be provided for you.
