Miranda v. Arizona, 1966
The Rights of the Accused
By Fidel Andrada
★★★★★★★★★★★★★★★★ Background of the Case ★★★★★★★★★★★★★★★★
Ernesto Miranda had been arrested at his home in Phoenix, Arizona, and accused of kidnapping and rape. Questioned at the police station by two police officers, he was not advised of his right to an attorney nor his right to remain silent. After two hours of interrogation, he signed a written confession to the crimes. At his trial, he was found guilty and sentenced to 20 to 30 years in prison. He took his case to the United States Supreme Court.
★★★★★★★★★★★★★★★★Constitutional Issue ★★★★★★★★★★★★★★★★
The Fifth Amendment of the Constitution guarantees that “no person . . . shall be compelled in any criminal case to be a witness against himself. . . .” This right was made part of the Bill of Rights to prevent a tyrannical government from forcing accused persons to confess to crimes they may or may not have committed. Miranda’s case before the Supreme Court was based on this Fifth Amendment protection. The Court accepted the case in order to explore and clarify certain problems arising from earlier decisions related to the rights of individuals taken into police custody. The precise question that the Court explored was under what circumstances an interrogation may take place so that a confession made during the interrogation would be constitutionally admissible in a court of law.
★★★★★★★★★★★★★★ The Supreme Court’s Decision ★★★★★★★★★★★★★★
The Supreme Court overturned Miranda’s conviction in a 5 to 4 decision. Chief Justice Earl Warren wrote the majority opinion. The Court’s ruling centered on what happens when a person is taken into custody. No statement from the suspect, the Court held, may be used when it stems from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom in any significant way.
Warren noted that a suspect under interrogation is subject to great psychological pressures designed “to overbear the will,” and that questioning often takes place in an environment “created for no other purpose than to subjugate the individual to the will of his examiner.” In overturning Miranda’s conviction, the Court intended “to combat these pressures and to permit a full opportunity to exercise the privilege against self-incrimination. . . .”
A person in police custody “or otherwise deprived of his freedom…must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney, one will be appointed for him prior to any questioning if he so desires,” Warren stated.
Once these warnings are given, the individual in custody may choose to stop answering questions, or may halt the interrogation until his attorney is present. Otherwise, he may waive his exercise of these rights. In such a case, there would be “a heavy burden . . . on the Government to demonstrate that the defendant knowingly and intelligently waived his privilege against self-incrimination and his right to …counsel.”
The Miranda ruling applies only to interrogations. The Court emphasized that such safeguards were “not intended to hamper the traditional function of police officers in investigating crime. . . .” The ruling was not meant to bar “general on-the-scene questioning as to facts surrounding a crime or other general questioning of citizens in the fact-finding process. . . .” In addition, the Chief Justice declared, the Fifth Amendment does not bar voluntary statements from a person who, for example, enters a police station “. . . to confess to a crime, or a person who calls the police to offer a confession or any other statement he desires to make.”
The Miranda ruling has led to the practice now followed routinely by arresting police officers and other law enforcement officials during which they read a suspect his or her Miranda rights.
★★★★★★★★★★★★★★★★★★ Dissenting Opinion ★★★★★★★★★★★★★★★★★★
Justices John Marshall Harlan, Tom C. Clark, Potter Stewart, and Byron White dissented. They saw no historical precedent for the majority position and feared the decision could weaken law enforcement. Justice White condemned the majority for creating law enforcement directives he viewed as inflexible, while at the same time leaving many unanswered questions.