Miranda v. Arizona

Miranda v. Arizona (No. 759) 384 U.S. 436,86 S.Ct. 1692, 16 L.Ed.2d 694 (1966) Parties Miranda (Petitioner) vs. Arizona (Respondent) Procedure Arizona Supreme Court held that Miranda’s constitutional rights were not violated and affirmed conviction (petitioner lost) United States Supreme Court reversed the Arizona Supreme Court’s decision and said Miranda was not told of his right to an attorney or his right against self-incrimination so his statements in his original trial were inadmissible. Facts On March 3, 1963, an 18-year-old girl was kidnapped and raped near Phoenix, Arizona. Ten days later, on March 13, 1963, Ernesto Miranda was arrested in his home and taken to a police station where the victim of the crime picked him out of a lineup. Miranda was taken to “Interrogation Room No. 2” and two hours later, two police officers emerged with a written confession signed by Miranda. Mr. Miranda was not told that he had a right to have an attorney present, or that he had the right to remain silent before, during, or after he was questioned. Miranda’s confession was admitted into evidence and used to convict him at trial, where the jury found Miranda guilty. On appeal, the Arizona Supreme Court held that Miranda’s constitutional rights were not violated because Miranda did not specifically ask for counsel. Issue Are statements obtained from an individual who is unaware if his right to counsel and right against self-incrimination admissible in a criminal trial? Is the Fifth Amendment right against self-incrimination violated when a suspect is interrogated in custody without being informed of his right to counsel and right against self-incrimination? Are government officers required to notify arrested people of their Fifth Amendment rights to counsel and against self-incrimination before they interrogate defendants? Rule The interrogating individual first needs to inform individuals of their Fifth Amendment rights to remain silent, to have counsel appointed if it cannot be afforded, and the explanation that anything they say can and will be used against them in a court of law. If one wishes to waive these rights, they need to formally waive their rights. Until these warnings are given, no evidence obtained as a result of interrogation can be used against the defendant in a court of law. Application The United States Supreme Court used the Sixth Amendment right to counsel and the Fifth Amendment Self-Incrimination Clause to implement the procedure now used on all arrested individuals, commonly referred to as the Miranda warnings. This case held that all individuals needed to be informed of their right to remain silent as well as their right to counsel, and that counsel could be appointed to them if they could not afford counsel. The United States Supreme Court brought about the example of the 1912 Judge’s Rules used in England that require a warning to be given by a police officer as soon as they have evidence that affords grounds for suspicion as well as that any statement to be used in court must have been taken without questioning by police. The precedent used for this case was Escobedo v. Illinois, where the United States Supreme Court held that if a suspect has been taken into custody, interrogated, given a statement, and been denied a lawyer, the police have unconstitutionally denied him of his right to the assistance of counsel as given in the Sixth Amendment and made obligatory to the states by the Fourteenth Amendment. In this case, the Court also reversed the decisions of two other cases, Vignera v. New York and Westover v. United States, which affirming the reversal of California v. Stewart. In Vignera v. New York, the defendant admitted orally to the crime, and then signed a statement after being questioned by the assistant district attorney the same day. In Westover v. United States, the defendant was given to the FBI by the local authorities after being detained and interrogated. After more interrogation, the federal officers obtained signed statements from the defendant. In California v. Stewart, the local police held the defendant for five days and interrogated him nine times before getting a statement from him. The United States Supreme Court also used Mallory v. Hogan as a precedent, where it was held that the government needed to produce evidence against the defendant and that the defendant must be guaranteed the right to remain silent unless he so chooses. This was later called the voluntariness doctrine and concerns interrogation practices which result in pressure on the defendant that causes confessions that would not have occurred without the said pressure. The United States Supreme Court stated that Rule 5(a) of the Federal Rules of Criminal Procedure and the use of that rule in McNabb v. United States gave the Court little reason to deal with investigations in the past. The importance of a lawyer is presented in the precedent of Crooker v. California, where it was held that the presence of a lawyer can help to have correctly reported statements that are fully accurate. Another precedent of this case was Gideon v. Wainwright as well as Douglas v. California, where it was decided that denial of counsel to accused that cannot afford it during interrogation while allowing counsel for those that could afford it was a violation of the Fourteenth Amendment. The precedent of Johnson v. Zerbst decided that there must be high standards of proof for the waiving of constitutional rights, including the right to counsel and the Fifth Amendment right against self-incrimination. Carnley v. Cochran decided that the record must show that all accused were offered counsel and knowledgeably refused the offer before the right to counsel can be considered officially waived. Conclusion The United States Supreme Court found in favor of the petitioner, Miranda, in that the Fifth, Sixth, and Fourteenth Amendments guarantee the right to counsel and the right against selfincrimination, and that all suspects must be informed of these rights before any questioning can occur. This sets a precedent for all other cases involving statements from suspects that are selfincriminating, as well as all cases involving the absence of counsel or the waiving of the right to counsel. Discussion Miranda v. Arizona was a 5-4 decision where the majority declared that all citizens have the right to counsel and the right against self-incrimination under the Fifth, Sixth, and Fourteenth Amendments, and that these rights must be announced to all people in custody before any interrogation can occur. Justice Harlan, Stewart, and White were the dissenting opinion, and Justice Clark dissented in Miranda v. Arizona, Vignera v. New York, and Westover v. United States and concurred in California v. Stewart. The dissenting opinion voiced by Justice Clark focused on the Due Processes Clauses of the Fifth and Fourteenth Amendments rather than the Fifth Amendment rule that was focused on in the concurring opinion. Justice Clark believed that there was not enough evidence to permit the full sweep that occurred because of this decision, and that it would be best for everyone to move slowly toward the goal of interrogation without pressure and statements without coercion. Justice Clark believed that episodes of police brutality and of coerced statements were rare exceptions rather than something that happened frequently in the United States criminal justice system. The other dissenting opinion shared by Justice Stewart and Justice White and voiced by Justice Harlan was against this ruling because they believed the new required warnings and waivers did not guard against police brutality but instead discouraged any confession at all. They did not agree that the premises of this case as well as Escobedo v. Illinois were sustained by precedents under the Fifth Amendment. The dissenting opinions thought that this holding would do nothing more than slow down the investigation and apprehension of suspects, resulting in discriminating treatment. The dissenting opinion believed that there needed to be a more flexible rule in place rather than a hard set of rules that would have to be applied to every suspect of every case being investigated. The ruling of this case is good for society, as well as anyone accused of crimes, because it ensures that everyone is well aware of their rights and people are less likely to get convicted based off a coerced confession that cannot be overturned. It protects the people from potential unconstitutional activities of the police, as well as from themselves by creating the Miranda warnings that are now read to every person taken into custody to ensure they are aware of their right to counsel and their right against self-incrimination. This ruling also holds law enforcement of all kinds, as well as courtrooms and prosecutors, accountable for their actions and provides a step-by-step process to ensure equal treatment for all citizens in custody. It is good for the court system, and especially the court rooms, because people that are passing judgement on a defendant know that if there is a confession, it was taken with free will and knowledge of what that statement could do in court. From this case, the Supreme Court as well as the states created the Miranda warnings, which are now a part of training for all police officers and required to be read to all suspects before any questioning can occur. Normally, the Miranda warnings are read to the suspect as soon as they are taken into custody to ensure that a defendant going to trial cannot say they were unaware of the consequences of their actions. Traditionally, the Miranda rights are read by the police officer to the suspect as follows, “you have the right to remain silent. Anything you say can and will be used against you in a court of law. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you. Do you understand the rights that I have just read to you?”. Although the warnings are short, they do qualify as warning the individual of their rights before any damage can be done. In this case, the Supreme Court used the Fifth, Sixth, and Fourteenth Amendments to come up with the idea that warnings must be given to all who are taken into custody before they can be questioned by police. The right to counsel and the right against self-incrimination are taken from the Constitution, but the need to warn individuals of these rights is something the Court came up with to satisfy the Fourteenth Amendment right to equality of all citizens. Some people may not know their Constitutional rights, so the Miranda warnings are a way to ensure an equal playing field for anyone who is arrested, because they all will know their rights and how to exercise them or waive them if they so choose. This ruling sets a precedent for many other future cases, as well as concurs with several other cases in the past and during the time of this case. Escobedo v. Illinois, Vignera v. New York, Westover v. United States and California v. Stewart are mentioned in the application as cases during this time that concurred with the results of Miranda v. Arizona. In all cases from Miranda onward, police were required to give anyone in custody their Miranda warnings, and they were named Miranda warnings after this case because it was felt that this case was important enough to merit that. This case was a precedent in the Harris v. New York case, where it was held that statements preceded by defective warnings and declared inadmissible could be used to impeach the defendant’s credibility if they were to take up the stand in their own defense. In this case, the Court noted that some language in the Miranda holding could be read as barring the use of statements obtained in violation of the Miranda warnings for any purpose, but that this was not the intention nor what would be done. This case was used as a precedent in Oregon v. Hass, where the Court ruled that even if the defendant asks for a lawyer, the resulting incriminating statements that occur from continued questioning could be used to impeach one’s credibility on the stand. Ultimately, this ruling gave the police everything to gain from continuing to question a suspect after they ask for a lawyer. The wording in the Miranda case led to some miscommunication; some of this miscommunication was settled in Michigan v. Mosley, where it was held that under certain circumstances, if the police cease questioning after the suspect asks for a lawyer, they can try again later after giving the suspect a second round of Miranda warnings. Michigan v. Mosley elaborated on the notions set by Miranda so they could be easily applied to other cases. The precedent set by Miranda has been used countless times since the case in 1966 to grow the rights of defendants and keep the actions of law enforcement in line.s