Facts of the Case Police arrest Ernesto Miranda after the victim identifies him in lineup Police interrogate Miranda for two hours
Facts of the Case Miranda confesses in writing to charges of rape and kidnapping. At trial, the prosecutor uses confession to obtain conviction. Miranda is sentenced to 20-30 yrs on each count.
Miranda appeals to the Supreme Court 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. Do the police have an obligation to ensure that an accused person is aware of their rights? 2. If so, at what point in the criminal justice process must the defendant learn of these rights?
5 th & 6 th Amendments Fifth Amendment: no person "shall be compelled in any criminal case to be a witness against himself...." Sixth Amendment: "In all criminal prosecutions, the accused shall enjoy the right... to have the assistance of counsel for his defense."
Legal Precedents Fifth Amendment protects individuals from forced confessions. (Brown v. Mississippi, 1936) Persons accused of felonies have a fundamental right to an attorney (Gideon v. Wainwright, 1963) 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 5-4 ruling in favor of Miranda Police must ensure that defendants are aware of their rights before they are interrogated in custody. They have the right to remain silent Anything they say may be used against them in court They have the right to an attorney, either retained by them or appointed by the court They may waive these rights, but they retain the right to ask for an attorney any time during the interrogation
Bottom Line: Suspect must be in custody This means a reasonable person believes they are not free to leave. Suspect must be under interrogation This is any direct questioning by officers where the officer believes an answer could incriminate the suspect.
Footnotes: Miranda went back to court for another trial 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: 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
CASE 1: Rhode Island v. Innis (1980) 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) 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) 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 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? 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 Traffic violations When the police are preserving public safety Spontaneous remarks Routine booking questions Undercover plain clothes officers in jail