Legal Lens: Viewing Law Through Ingrum Expertise
CITATION: 384 U.S. 436, 10 Ohio Misc. 9, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966)
BRIEF FACT SUMMARY: The defendants offered incriminating evidence during police interrogations without prior notification of their rights under the Fifth Amendment of the United States Constitution.
SYNOPSIS OF RULE LAW: Government authorities need to inform individuals of their Fifth Amendment constitutional rights prior to an interrogation following an arrest.
FACTS: The Supreme Court of the United States consolidated four separate cases with issues regarding the admissibility of evidence obtained during police interrogations. The first Defendant, Ernesto Miranda, was arrested for kidnapping and rape. Mr. Miranda was an immigrant, and although the officers did not notify Mr. Miranda of his rights, he signed a confession after two hours of interrogation. The signed statement included a statement that Mr. Miranda was aware of his Constitutional rights. The second Defendant, Michael Vignera, was arrested for robbery. Mr. Vignera orally confessed to the robbery to the first officer after the arrest, and he was held in detention for eight hours before he made an admission to an assistant district attorney. There was no evidence that he was ever notified of his Fifth Amendment rights.
The third Defendant, Carl Calvin Westover, was arrested for two robberies. Mr. Westover was interrogated for over fourteen hours by the police, and then he was handed over to some FBI agents, who were able to obtain a signed confession from Mr. Westover. The authorities never notified Mr. Westover of his Fifth Amendment constitutional rights. The fourth Defendant, Roy Allen Stewart, was arrested, along with members of his family (although there was no evidence of any wrongdoing by his family) for a series of purse snatches. There was no evidence that Mr. Stewart was told of his Fifth Amendment rights. After nine interrogations, Mr. Stewart admitted to the purse snatches.
ISSUE: Whether the government is required to notify the arrested defendants of their Fifth Amendment constitutional rights against self-incrimination before they interrogate the defendants?
HELD: The Supreme Court of the United States held that the government needs to notify arrested defendants of their Fifth Amendment constitutional rights, specifically: their right to remain silent; an explanation that anything they say could be used against them in court; their right to an attorney; and their right to have an attorney appointed to represent them if they cannot afford an attorney. Without this notification, anything admitted by an arrestee in a custodial interrogation will not be admissible in court.
DISSENT: Justice Tom Clark argued that the Due Process Clauses of the Fifth and Fourteenth Amendments to the Constitution would apply to interrogations. There is not enough evidence to demonstrate a need to apply a new rule as the majority finds here. The second dissent written by Justice John Harlan also argues that the Due Process Clauses should apply. Justice Harlan further argues that the Fifth Amendment rule against self-incrimination was never intended to forbid any and all pressures against self-incrimination. Justice Byron White argued that there is no historical support for broadening the Fifth Amendment of the Constitution to include the rights that the majority extends in their decision. The majority is making new law with their holding.
DISCUSSION: The majority notes that once an individual chooses to remain silent or asks to first see an attorney, any interrogation should stop immediately. Further, the individual has the right to stop the interrogation at any time, and the government will not be allowed to argue for an exception to the notification rule. Of course, this case is the basis for the “Miranda Rights” that we all enjoy and that we have all seen and heard on TV and in the movies for years.
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