Miranda v. Arizona Summary
The Supreme Court ruled in favor of a man convicted on the basis of a confession that was elicited during the course of Arizona police interrogations which were conducted without warnings of the right to an attorney—warnings which are required to be provided to ensure preservation of the Fifth Amendment’s “privilege against self-incrimination”.
Key Players in Miranda v. Arizona
- 1Appellant: Ernesto Miranda, who was questioned about and confessed to a crime in police custody without being informed of his right to have an attorney present while communicating with police.
- 2Appellee: The State of Arizona and, specifically, the Phoenix Police Department, who detained, questioned, and elicited a confession from Miranda without warning him that he had a right to have an attorney present during questioning.
Miranda v. Arizona Brief
The central theme of this case was Miranda warnings and the protections against self-incrimination included in the Fifth Amendment.
Miranda v. Arizona Facts
Miranda was questioned in police custody in Arizona without being given a warning that he had a right to have an attorney present during questioning and that he had a right to remain silent while in police custody. The Phoenix police arrested Miranda at his house and then took him into custody at the station. While in custody, Miranda, who was described as being severely mentally disturbed and whose home country did not use English as its primary language, was questioned by police in the “interrogation room” for two hours by a pair of officers. At no time did the officers tell him that he had the right to have an attorney present. While in custody, Miranda confessed to a crime and signed a written confession with a printed paragraph at the top of the document stating that his confession was voluntary and that Miranda drafted it having “full knowledge of his legal rights” as well as an “understanding that any statement” he made may be used against him. Miranda was subsequently convicted of kidnapping and rape after a trial in which the written confession was allowed to be used as evidence against him. In that same trial, testimony of the interrogating officers which confirmed Miranda’s oral confession was also admitted into evidence. Key to the Supreme Court of Arizona’s finding that the elicitation of Miranda’s confession and the use of his confession at trial were not unconstitutional was the fact that no request for counsel was made by Miranda. Miranda appealed to the U.S. Supreme Court from the Arizona Supreme Court decision.
The Miranda v. Arizona Decision
The outcome of this case was the overturning of Miranda’s conviction based on the finding that Miranda was not given appropriate warnings of his right to an attorney prior to questioning by the police and his ensuing confession. The Court found that the “privilege against self-incrimination” included in the Fifth Amendment was not preserved for Miranda because of this failure to warn Miranda. The Court’s basic ruling was that, in order to use statements gathered from a custodial interrogation as evidence in a trial, a prosecutor must “demonstrate the use of procedural safeguards effective to secure the privilege against self-incrimination”. The Court went on to state that the specific requirements for those safeguards include the following: a warning of the right to remain silent, a warning that anything the suspect says may be used against him, and a warning that the suspect has a right to an attorney. It described how waiver of those rights is allowed if such waiver is voluntary, knowing, and intelligent. Silence does not constitute waiver. The Court noted that, during interrogation, once the suspect asks for an attorney, any present questioning must cease. The Court went on to state that if a suspect refuses to be questioned at all, the police must not question him and, if the suspect asks for an attorney after he begins to speak, questioning must then stop.
The Court warned that warnings of rights must be given “at the outset” of questioning to protect defendants against the typically coercive elements of the standard interrogation environment. The Court expressed particular concern with failure to warn a suspect of his rights in the particular situation of “incommunicado interrogation of individuals in a police-dominated atmosphere” and with interrogation techniques and strategies which are designed to elicit, sometimes false, confessions without actual coercion. In discussing such circumstances, the Court acknowledged that, in Miranda’s case, his statement was not actually “involuntary” as it would likely be in an incommunicado and highly coercive environment. The Court described how there must be evidence of some actual “undertaking” by police to preserve the privilege against self-incrimination because many interrogation environments are characterized by intimidation, overt or otherwise.
The Court also held that government interest in questioning potential criminals is not of greater importance than upholding the privilege against self-incrimination.
Key Takeaways for Law Students
- 1If there is no evidence available of a suspect having been given appropriate Miranda warnings, the courts will neither presume that a suspect has been properly informed of his rights nor conclude that the privilege against self-incrimination has been protected.
- 2Even if a suspect who is in custody does not ask for an attorney, she must be advised of her right to request counsel or her right to have counsel present during questioning to avoid self-incrimination.
- 3To waive the right to an attorney, a suspect must give a “knowing and intelligent waiver” of his rights. Signing a confession statement that acknowledges legal rights in general does not constitute such waiver.