Miranda v. Arizona
Issues: Self-Incrimination, Due Process
Background:
- Ernesto Miranda was a poor man who lived in Arizona in 1963. A woman accused Miranda of committing a crime against her. The police arrested Miranda and asked him questions about the crime for two hours.
- In the United States, people who are accused of crimes have certain rights granted by the Constitution. The Fifth Amendment of the Constitution says that they have the right to be silent. The Sixth Amendment of the Constitution says that they have the right to have a lawyer to help defend themselves.
- The police did not tell Miranda that he had these rights when they arrested him. After the police were finished asking Miranda questions, he signed a confession. The police used his confession in the trial and Miranda was convicted of the crime. The judge decided he should serve 20 to 30 years in prison for each crime.
- Miranda appealed his case to the highest court in Arizona, called the Supreme Court of Arizona. His attorney argued that his confession should not have been used as evidence in his trial because Miranda had not been informed of his rights, and no attorney had been present to assist him during his interrogation. The government argued that Miranda had been convicted of crimes before, and so he should have known his rights. The Arizona Supreme Court denied his appeal and upheld Miranda's conviction.
- The Supreme Court of the United States agreed to hear Miranda's case. The decision in Miranda v. Arizona was handed down in 1966.
- In a 5-4 opinion, the Supreme Court ruled in favor of Miranda. The majority opinion, written by Chief Justice Earl Warren, concluded that defendants arrested under state law must be informed of their constitutional rights against self-incrimination and to representation by an attorney before being interrogated when in police custody. Justices Clark, Harlan, Stewart and White dissented.
- In their majority opinion, the justices explained that the Fifth Amendment right against self-incrimination is fundamental to our system of justice, and is “one of our Nation’s most cherished principles.” This guarantee requires that only statements freely made by a defendant may be used in court. The justices described some of the techniques used by police officers in interrogations. They observed that “the modern practice of in-custody interrogation is psychologically rather than physically oriented,” and cited the advantage police officers hold in custodial interrogations (interrogations that take place while the subject is in police custody). Because of these advantages, they concluded that “the very fact of custodial interrogation exacts a heavy toll on individual liberty, and trades on the weakness of individuals.”
- The Court ruled that in order to reconcile the necessary practice of custodial interrogations with the guarantees of the Fifth Amendment, police must ensure that defendants are aware of their rights before they are interrogated in custody. Because the right against self-incrimination is so important to our system of justice, a case by case determination made by police officers of whether each defendant understands his or her rights is not sufficient. Before interrogating defendants in police custody, they must be warned 1) that they have the right to remain silent 2) that anything they say may be used against them in court, 3) that they have the right to an attorney, either retained by them or appointed by the court, and 4) that they may waive these rights, but they retain the right to ask for an attorney any time during the interrogation, at which point the interrogation can only continue in the presence of a lawyer.
- The Supreme Court reasoned that because the right against self-incrimination is so fundamental, and because it is so simple to inform defendants of their rights, any statements made by defendants during a custodial interrogation in which the defendant has not been read his “Miranda rights” are inadmissible in both state and federal courts.
- Justice Harlan wrote the main dissent. He argued that the newly created rules did not protect against police brutality, coercion or other abuses of authority during custodial interrogations because officers willing to use such illegal tactics and deny their use in court were “equally able and destined to lie as skillfully about warnings and waivers.” Instead, he predicted that the new requirements would impair and substantially frustrate police officers in the use of techniques that had long been considered appropriate and even necessary, thus reducing the number of confessions police would be able to obtain. He concluded that the harmful effects of crime on society were “too great to call the new rules anything but a hazardous experimentation.”
Case# & Citation:
- Miranda v. Arizona, 384 U.S. 436 (1966)
- Landmark Cases of the U.S. Supreme Court. (n.d.). Retrieved April 15, 2015, from http://www.streetlaw.org/en/landmark/cases/miranda_v_arizona