Miranda v. Arizona

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Miranda v. Arizona (consolidated with Westover v. United States, Vignera v. New York, and California v. Stewart), 384 U.S. 436 (1966), was a landmark 5-4 decision of the United States Supreme Court which was argued February 28-March 1, 1966 and decided June 13, 1966. The Court held that criminal suspects must be informed of their right to consult with an attorney and of their right against self-incrimination prior to questioning by police. The Miranda warning required by the Supreme Court in this case is an example of a prophylactic rule formulated by the judiciary in order to protect a constitutional right.

Background of the case

The Legal Aid Movement

During the 1960s, a movement which provided defendants with legal aid emerged from the collective efforts of various bars. In the civil realm, it led to the creation of the Legal Services Corporation under the Great Society program of Lyndon Baines Johnson. Escobedo v. Illinois, 378 U.S. 478 (1964), a case which closely foreshadowed Miranda, provided for the presence of counsel during police interrogation. This reformist impulse extended to a concern over police interrogation practices, which were considered by many to be barbaric and unjust. Coercive interrogation tactics were known in period slang as the "third degree."

Arrest and conviction

In 1963, Ernesto Arturo Miranda (Ernest Arthur Miranda) (born in Mesa, Arizona in 1941, and living in Phoenix, Arizona) was arrested for rape. He later confessed to robbery and attempted rape under interrogation by police. At trial, prosecutors offered only his confession as evidence. Miranda was convicted of rape and kidnapping and sentenced to 20 to 30 years imprisonment on each charge, with sentences to run concurrently. Miranda's court-appointed lawyer, Alvin Moore, appealed to the Arizona Supreme Court which affirmed the trial court's decision. In affirming, the Arizona Supreme Court emphasized heavily the fact that Miranda did not specifically request counsel.

The U.S. Supreme Court's decision

Chief Justice Earl Warren, a former prosecutor, delivered the opinion of the Court, ruling that due to the coercive nature of custodial interrogation by police (to bolster his point, Warren controversially cited several police training manuals), no confession could be admissible under the Fifth Amendment self-incrimination clause and Sixth Amendment right to an attorney unless a suspect had been made aware of his rights and the suspect had then waived them. Thus, Miranda's conviction was overturned.
" 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. "

The Court also made clear what had to happen if the suspect chose to exercise his rights:
" If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease ... If the individual states that he wants an attorney, the interrogation must cease until an attorney is present. At that time, the individual must have an opportunity to confer with the attorney and to have him present during any subsequent questioning.

lthough the ACLU had urged the Supreme Court to require the mandatory presence of a "station-house" lawyer at all police interrogations, Warren refused to go that far, or to even include a suggestion that immediately demanding a lawyer would be in the suspect's best interest. Either measure would make interrogations useless because any competent defense attorney would instruct his client to say nothing to the police.

Warren pointed to the existing practice of the FBI and the rules of the Uniform Code of Military Justice, both of which required notifying a suspect of his right to remain silent; the FBI warning included notice of the right to counsel.

However, the dissenting justices thought that the suggested warnings would ultimately lead to such a drastic effect ? they apparently believed that once warned, suspects would always demand attorneys and deny the police the ability to seek confessions?and ...