Miranda v Arizona
Warren, CJ
FACTS
- Case represents the consolidation of four cases
- Defendant in each case confessed guilt after being
subjected to a variety of interrogation techniques without
being informed of his Fifth Amendment rights during an
interrogation
1. Ernesto Miranda
- Mr. Miranda was an immigrant, and although
the officers did not notify Mr. Miranda of his
rights, he signed a confession
- Ernesto Miranda was arrested in his house and
brought to the police station where he was
questioned by police officers in connection with
kidnapping and rape
- After 2 hours of interrogation, the police
obtained a written confession from Miranda
- The written confession was admitted into
evidence at trial despite the objection of the
defense attorney and the fact that the police
officers admitted that they had not advised
Miranda of his right to have an attorney present
during the interrogation
- The jury found Miranda guilty
- On appeal, the Supreme Court of Arizona
affirmed and held that Mirandas constitutional
rights were not violated because he did not
specifically request counsel
2. Michael Vignera
- Mr. Vignera was arrested for robbery
- He orally admitted to the robbery to the first
officer after the arrest, and 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
5th Amendment Constitutional rights
3. Carl Calvin Westover
- Mr. Westover was arrested for two robberies
- He was questioned for over 14 hours by the local
police
- He was handed to the FBI who was able to get
signed confessions from him
- He was not notified of his 5th Amendment Rights
4. Roy Allen Stewart
- He was arrested along with members of his
family for a series of purse snatches
- There was no evidence of any wrongdoing by his
family
- He was not notified of his 5th Amendment rights
- After nine interrogations, he admitted to the
crimes
ISSUE
WON accused should be notified of their rights against self-
incrimination
RULING/DISCUSSION
Yes, they should be notified.
The prosecution may not use statements, whether exculpatory or
inculpatory, stemming from questioning initiated by law
enforcement officers after a person has been taken into custody or
otherwise deprived of his freedom of action in any significant way,
unless it demonstrates the use of procedural safeguards effective to
secure the Fifth Amendment's privilege against self-incrimination.
- The atmosphere and environment of
incommunicado interrogation as it exists today is
inherently intimidating, and works to undermine
the privilege against self-incrimination.
- The privilege against self-incrimination
guarantees to the individual the "right to remain
silent unless he chooses to speak in the
unfettered exercise of his own will," during a
period of custodial interrogation as well as in the
courts or during the course of other official
investigations.
- the need for protective devices to make the
process of police interrogation conform to the
dictates of the privilege
- the person in custody must, prior to
interrogation, be clearly informed that he has
the right to remain silent, and that anything he
says will be used against him in court; he must
be clearly informed that he has the right to
consult with a lawyer and to have the lawyer
with him during interrogation, and that, if he is
indigent, a lawyer will be appointed to
represent him
- If the individual indicates, prior to or during
questioning, that he wishes to remain silent, the
interrogation must cease
- Where an interrogation is conducted without
the presence of an attorney and a statement is
taken, a heavy burden rests on the Government
to demonstrate that the defendant knowingly
and intelligently waived his right to counsel.
- Where the individual answers some questions
during in-custody interrogation, he has not
waived his privilege, and may invoke his right to
remain silent thereafter.
- The warnings required and the waiver needed
are, in the absence of a fully effective equivalent,
prerequisites to the admissibility of any
statement, inculpatory or exculpatory, made by
a defendant
The limitations on the interrogation process required for the
protection of the individual's constitutional rights should not cause
an undue interference with a proper system of law enforcement, as
demonstrated by the procedures of the FBI and the safeguards
afforded in other jurisdictions.
In each of these cases, the statements were obtained under
circumstances that did not meet constitutional standards for
protection of the privilege against self-incrimination.
DISSENT: Clark, J.
- the majoritys opinion created an unnecessarily
strict interpretation of the Fifth Amendment that
curtails the ability of the police to effectively
execute their duties
- the state should have the burden to prove that
the suspect was aware of his rights during the
interrogation, but that statements resulting
from interrogation should not be automatically
excluded if the suspect was not explicitly
informed of his rights
DISSENT: Harlan, J.
- the judicial precedent and legislative history
surrounding the Fifth Amendment does not
 support the view that the Fifth Amendment
prohibits all pressure on the suspect
- there was no legal precedent to support the
requirement to specifically inform suspects of
their rights
DISSENT: White, J.
- the Fifth Amendment only protects defendants
from giving self-incriminating testimony if
explicitly compelled to do so
- custodial interrogation was not inherently
coercive and did not require such a broad
interpretation of the protections of the Fifth
Amendment
- Such an interpretation harms the criminal
process by destroying the credibility of
confessions