Miranda v. Arizona
1966
Read Miranda v. Arizona
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Parties
Facts
Issue
Facts of the Case
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Police arrest Ernesto Miranda after the victim
identifies him in lineup
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Police interrogate Miranda for two hours
Facts of the Case
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Miranda confesses in
writing to charges of rape
and kidnapping.
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At trial, the prosecutor uses
confession to obtain
conviction.
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Miranda is sentenced to
20-30 yrs on each count.
Miranda appeals to the Supreme Court
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Miranda argues that his confession should
have been excluded because he had not
been informed of his right not to confess, and
there was no attorney present during
interrogation
Question Before the Court
1.
2.
Do the police have an obligation to
ensure that an accused person is aware
of their rights?
If so, at what point in the criminal justice
process must the defendant learn of
these rights?
th
5
&
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6
Amendments
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Fifth Amendment: no person "shall be
compelled in any criminal case to be a
witness against himself. . . ."
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Sixth Amendment: "In all criminal
prosecutions, the accused shall enjoy the
right . . . to have the assistance of counsel for
his defense."
Legal Precedents
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Fifth Amendment protects individuals from forced
confessions. (Brown v. Mississippi, 1936)
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Persons accused of felonies have a fundamental right
to an attorney (Gideon v. Wainwright, 1963)
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When an accused person is denied the right to
consult with his attorney, his/her Sixth Amendment
right to counsel is violated (Escobedo v. Illinois,
1964).
Ruling
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5-4 ruling in favor of Miranda
Police must ensure that defendants are aware of
their rights before they are interrogated in custody.
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They have the right to remain silent
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Anything they say may be used against them in court
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They have the right to an attorney, either retained by
them or appointed by the court
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They may waive these rights, but they retain the right
to ask for an attorney any time during the interrogation
Bottom Line:
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Suspect must be in custody
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This means a reasonable person believes they
are not free to leave.
Suspect must be under interrogation
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This is any direct questioning by officers where
the officer believes an answer could incriminate
the suspect.
Footnotes:
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Miranda went back to court for another trial
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This time the confession could not be used
He was convicted again, this time because
he had confessed his crimes to his neighbor
The Supreme Court’s ruling did not prevent
the neighbor from disclosing the confession
Miranda was again sentenced to 20-30 years
Footnotes continued:
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When Miranda was paroled, he was arrested
again for possession of a handgun and put back
in prison (this time he was read his rights)
He was released again, and about 10 years
later, he was stabbed and killed in a bar fight.
In his pocket, were cards with the Miranda
warning that he was selling near the courthouse
to support himself
The police read the suspects their Miranda
rights
HOW CLEAR IS MIRANDA?
CASE 1: Rhode Island v. Innis (1980)
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Suspect was arrested for murder;
He was read his rights;
On the way to the police station, one cop said
to the other “God forbid a child finds the
murder weapon – they could hurt
themselves.”
The suspect tells and shows the cops where
the gun was
Can the suspects statements be used?
CASE 2: New York v. Quarles (1984)
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Woman approaches police; tells them she
has just been assaulted at gunpoint
Suspect who matches the description is
found in a nearby grocery mart
Suspect has an empty gun holster; cops
handcuff him, ask (without reading rights)
where the gun is and he tells the police “the
gun is over there.”
Is the gun and the statement admissible?
CASE 3: Illinois v. Perkins (1990)
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Suspect is in jail awaiting trial (not for murder)
Undercover agent is placed in the cellblock,
and gains a confession from the suspect
about a murder he had committed
Can the confession be used against the
suspect?
CASE 4: J.D.B. v. North Carolina 2011
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Suspect is 13 years old, accused of breaking
into homes and stealing items
At his school, J.D.B. was encouraged to “do the
right thing” by his school administrator, and was
questioned by an investigator. After he admitted
to stealing, he was told he could leave. He
stayed and answered more questions for 45
more minutes.
Should J.D.B.’s statement be admitted? Should
J.D.B.’s age and state of mind be considered?
When does Miranda not apply?
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Physical evidence: fingerprints, DNA,
handwriting samples, etc.
Corporations
When a defendant takes the stand in his own
defense
Immunity (not being prosecuted in exchange
for testimony)
If statute of limits has expired
Exceptions to Miranda
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Traffic violations
When the police are preserving public safety
Spontaneous remarks
Routine booking questions
Undercover plain clothes officers in jail