Miranda v.

Arizona

Citation. Miranda v. Ariz., 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694, 1966 U.S. LEXIS 2817, 10 Ohio
Misc. 9, 36 Ohio Op. 2d 237, 10 A.L.R.3d 974 (U.S. June 13, 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 (the
“Constitution”).
Synopsis of Rule of 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 (“Supreme Court”) consolidated four separate cases with
issues regarding the admissibility of evidence obtained during police interrogations.

The first Defendant, Ernesto Miranda (“Mr. 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 investigation. The signed statement included a statement that Mr.
Miranda was aware of his rights.

The second Defendant, Michael Vignera (“Mr. Vignera”), was arrested for robbery. Mr. Vignera orally
admitted 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
notified of his Fifth Amendment constitutional rights.

The third Defendant, Carl Calvin Westover (“Mr. Westover”), was arrested for two robberies. Mr.
Westover was questioned over fourteen hours by local police, and then was handed to Federal Bureau
of Investigation (“FBI”) agents, who were able to get signed confessions from Mr. Westover. The
authorities did not notify Mr. Westover of his Fifth Amendment constitutional rights.

The fourth Defendant, Roy Allen Stewart (“Mr. 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 notified of his rights. After nine interrogations, Mr. Stewart
admitted to the crimes.
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 government needs to notify arrested individuals 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 counsel; and their right to have counsel appointed to represent
them if necessary. Without this notification, anything admitted by an arrestee in an interrogation will
not be admissible in court.

Dissent. Justice Tom Clark (“J. Clark”) argued that the Due Process Clauses of the Fifth and Fourteenth
Amendments of 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 (“J. Harlan”) also argues that the Due Process Clauses
should apply. J. 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 (“J. 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 cease. 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.

Miranda v. Arizona (1966)

In Miranda v. Arizona (1966), the Supreme Court ruled that detained criminal suspects, prior to police
questioning, must be informed of their constitutional right to an attorney and against self-incrimination.
The case began with the 1963 arrest of Phoenix resident Ernesto Miranda, who was charged with rape,
kidnapping, and robbery. Miranda was not informed of his rights prior to the police interrogation.
During the two-hour interrogation, Miranda allegedly confessed to committing the crimes, which the
police apparently recorded. Miranda, who had not finished ninth grade and had a history of mental
instability, had no counsel present. At trial, the prosecution's case consisted solely of his confession.
Miranda was convicted of both rape and kidnapping and sentenced to 20 to 30 years in prison. He
appealed to the Arizona Supreme Court, claiming that the police had unconstitutionally obtained his
confession. The court disagreed, however, and upheld the conviction. Miranda appealed to the U.S.
Supreme Court, which reviewed the case in 1966.

The Supreme Court, in a 5-4 decision written by Chief Justice Earl Warren, ruled that the prosecution
could not introduce Miranda's confession as evidence in a criminal trial because the police had failed to
first inform Miranda of his right to an attorney and against self-incrimination. The police duty to give
these warnings is compelled by the Constitution's Fifth Amendment, which gives a criminal suspect the
right to refuse "to be a witness against himself," and Sixth Amendment, which guarantees criminal
defendants the right to an attorney.

The Court maintained that the defendant's right against self-incrimination has long been part of Anglo-
American law as a means to equalize the vulnerability inherent in being detained. Such a position,
unchecked, can often lead to government abuse. For example, the Court cited the continued high
incidence of police violence designed to compel confessions from a suspect. This and other forms of
intimidation, maintained the Court, deprive criminal suspects of their basic liberties and can lead to false
confessions. The defendant's right to an attorney is an equally fundamental right, because the presence
of an attorney in interrogations, according to Chief Justice Warren, enables "the defendant under
otherwise compelling circumstances to tell his story without fear, effectively, and in a way that
eliminates the evils in the interrogations process."
Without these two fundamental rights, both of which, the Court ruled, "dispel the compulsion inherent
in custodial surroundings," "no statement obtained from the defendant can truly be the product of his
free choice."

Thus, to protect these rights in the face of widespread ignorance of the law, the Court devised
statements that the police are required to tell a defendant who is being detained and interrogated.
These mandatory "Miranda Rights" begin with "the right to remain silent," and continue with the
statement that "anything said can and will be used against [the defendant] in a court of law." The police
are further compelled to inform the suspect of his or her right to an attorney and allow for (or, if
necessary, provide for) a defendant's attorney who can accompany him during interrogations. Because
none of these rights was afforded to Ernesto Miranda and his "confession" was thus unconstitutionally
admitted at trial, his conviction was reversed. Miranda was later retried and convicted without the
admission of his confession.

Miranda v. Arizona, in creating the "Miranda Rights" we take for granted today, reconciled the
increasing police powers of the state with the basic rights of individuals. Miranda remains good law
today.

MIRANDA V. ARIZONA

Following is the case brief for Miranda v. Arizona, United States Supreme Court, (1966)

Case Summary of Miranda v. Arizona:

Miranda was taken into custody by police for purposes of interrogation, where he later confessed.
Miranda was not informed of his Fifth Amendment right to remain silent or right to have counsel
present.
Evidence of each confession was used at trial. Miranda was convicted and appealed
United States Supreme Court held that a suspect must be informed of their Fifth Amendment rights
(right to remain silent and have an attorney present during interrogation) when taken into custody.
Miranda v. Arizona Case Brief
Statement of Facts:

Miranda was arrested at his home and brought to the police station for questioning. He was never
informed of his right to remain silent or right to have counsel present. After two hours of interrogation,
Miranda made incriminating statements including an oral and signed a written confession. Evidence of
the oral confession through police testimony and the written confession were later used against him at
trial. As a result, Miranda was found guilty of rape and kidnapping.

Procedural History:

Arizona trial court found Miranda guilty of rape and kidnapping. Upon appeal to the state supreme
court, the conviction was affirmed because Miranda did not specifically ask for counsel. Miranda then
joined several other defendants and petitioned to the Supreme Court of the United States for review.

Issue(s) and Holding:

Is the Fifth Amendment right against self-incrimination violated when an individual is taken into custody
for interrogation purposes without being informed of his constitutional rights to remain silent and have
counsel present? Yes.

Judgment:

Chief Justice Warren led the majority in Reversal.

Rule of Law or Legal Principle applied:

When taken into custody, an individual has a right against self-incrimination under the Fifth
Amendment, requiring the individual to be informed of his constitutional rights.

Reasoning:

The right against self-incrimination applies not only at trial but when a suspect is taken into police
custody. Since Miranda was not informed of his rights, his confession was coerced by police in violation
of the Fifth Amendment.
Yes. Once subject to custodial interrogation, the Fifth Amendment requires that a suspect is informed of
their constitutional rights to: remain silent, have an attorney present, if he cannot afford an attorney
one will be appointed to him and that any statement made may later be used against them at trial.

The court took into consideration common police tactics and police instruction manuals and determined
that each uncovered an interrogation procedure aimed at attaining confessions through coercive means.
For example, many occur when the suspect is isolated and put in unfamiliar or intimidating
surroundings.

The Court held that police are encouraged to use trickery and make the false promises necessary to
obtain a confession. Although such methods are not physically coercive, the interrogation process is
aimed at putting the suspect in an emotionally vulnerable state so his judgment is impaired. These
coercive tactics are a violation of the Fifth Amendment. To ensure that a confession is obtained
voluntarily, a suspect must be informed of his constitutional right against self-incrimination in addition
to the consequences of a waiver. A waiver of Fifth Amendment rights must be made voluntary,
intelligently and knowingly.

A suspect must also be informed that they have a right for counsel to be present. Indigent individuals
should receive the same right and will be provided counsel if they cannot afford private representation.
Denial of this right also constitutes a violation of the Fifth Amendment, as such presence can prevent
improperly coercive police tactics. When a suspect asserts his Fifth Amendment right to an attorney or
right to remain silent, the police must cease questioning.

Concurring/Dissenting Opinion(s):

Dissent (Harlan):
Such a holding frustrates the job of law enforcement. The Court’s definition of “voluntariness” is
inconsistent with precedent. The constitution does not prohibit intrusion by the government when
probable cause or a warrant is present.

Dissent (White):

The conclusion that spontaneous statements are admissible, while those responsive to police
questioning are coercive, conflicts with common sense. No evidence supports that all confessions made
during an in-custody interrogation are coerced. If such evidence did exist, nothing supports the
conclusion that having counsel present will yield in a less coercive interrogation.

Significance:

Miranda v. Arizona is the landmark case from which we get our “Miranda” warnings. These warnings
serve as a safeguard to protect individual rights, specifically once taken into custody.