Miranda v. Arizona

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MIRANDA v. ARIZONA
No. 759
SUPREME COURT OF THE UNITED STATES
384 U.S. 436; 86 S. Ct. 1602; 16 L. Ed. 2d 694; 1966 U.S.
February 28-March 1, 1966, Argued June 13, 1966, Decided *

* Together with No. 760, Vignera v. New York, on certiorari to the Court of Appeals of New York and No. 761, Westover v. United States, on certiorari to the United States Court of Appeals for the Ninth Circuit, both argued February 28-March 1, 1966; and No. 584, California v. Stewart, on certiorari to the Supreme Court of California, argued February 28-March 2, 1966.

PRIOR HISTORY:
CERTIORARI TO THE SUPREME COURT OF ARIZONA.

DISPOSITION: 98 Ariz. 18, 401 P. 2d 721; 15 N. Y. 2d 970, 207 N. E. 2d 527; 16 N. Y. 2d 614, 209 N. E. 2d 110; 342 F.2d 684, reversed; 62 Cal. 2d 571, 400 P. 2d 97, affirmed.

SUMMARY: The instant cases deal with the admissibility of statements obtained from an individual who is subjected to custodial police interrogation, and the necessity for procedures which assure that the individual is accorded his privilege against self-incrimination. Without specific concentration on the facts of these cases, the Supreme Court of the United States, in an opinion by Warren, Ch. J., expressing the views of five members of the Court, laid down the governing principles, the most important of which is that, as a constitutional prerequisite to the admissibility of such statements, the suspect must, in the absence of a clear, intelligent waiver of the constitutional rights involved, be warned prior to questioning that he has a right to remain silent, that any statement he does make may be used as evidence against him, and that he has a right to the presence of an attorney, either retained or appointed. Clark, J., dissenting in part and concurring in part, expressed the view that the admissibility of a confession obtained by custodial interrogation should depend on the “totality of circumstances.” Harlan, Stewart, and White, JJ., dissented, expressing the view, in an opinion written by Mr. Justice Harlan, that the decision of the Court represents poor constitutional law and entails harmful conseque es for the country at large, and in an opinion written by Mr. Justice White, that the proposition that the privilege against self-incrimination forbids incustody interrogations without the warnings specified above and without a clear waiver of counsel has no significant support in the history of the privilege or in the language of the Fifth Amendment.

In No. 759 the defendant was arrested by the police and taken to a special interrogation room where he signed a confession which contained a typed paragraph stating that the confession was made voluntarily with full knowledge of his legal rights and with the understanding that any statement he made might be used against him. At his trial in an Arizona state court, at which the confession was admitted in evidence, he was convicted of kidnapping and rape. On appeal, the Supreme Court of Arizona affirmed. (98 Ariz 18, 401 P2d 721.) On certiorari, the Supreme Court of the United States reversed, holding that defendant’s confession was inadmissible because he was not in any way apprised of his right to counsel nor was his privilege against self-incrimination effectively protected in any other manner. Clark, J., and Harlan, Stewart, and White, JJ., dissented.

In No. 760 the defendant made an oral confession to the police after interrogation in the afternoon, and then signed an inculpatory statement upon being questioned by an assistant district attorney later the same evening. At his trial in a New York State court on a charge of robbery, the defense was precluded from making any showing that warnings of his right to counsel and his right to be silent had not been given. His conviction was affirmed by the Appellate Division, Second Department (21 App Div 2d 752, 252 NYS2d 19), and by the Court of Appeals (15 NY2d 970, 259 NYS2d 857, 207 NE2d 527, remittitur amended, 16 NY2d 614, 261 NYS2d 65, 209 NE2d 110.) On certiorari, the Supreme Court of the United States reversed on the ground that the defendant was not warned of any of his rights before the questioning by the police and by the assistant district attorney, and that no other steps were taken to protect these rights. Clark, J., and Harlan, Stewart, and White, JJ., dissented.

In No. 761 the defendant was arrested by Kansas City police as a suspect in Kansas City robberies, and was interrogated in the private interview room of the police department for a lengthy period. He was then handed over to the FBI and interrogated by three special agents, who after some 2 hours obtained two signed confessions to each of two California robberies (federal offenses). At his trial in the United States District Court for the Northern District of California, at which the confessions obtained by the FBI were admitted in evidence, he was convicted of the California robberies, and his conviction was affirmed by the Court of Appeals for the Ninth Circuit. (342 F2d 684.) On certiorari, the Supreme Court of the United States reversed on the ground that the defendant did not knowingly and intelligently waive his right to remain silent and his right to consult with counsel prior to the time he made the confessions, since the interrogations, though conducted by two legally distinct law enforcement authorities, had the impact on him of a continuous period of questioning. Clark, J., and Harlan, Stewart, and White, JJ., dissented in separate opinion.

In No. 584 local California police held the defendant in the station for 5 days and interrogated him on nine separate occasions before they secured his confession, defendant denying the alleged offenses through eight of the interrogations. At his trial in a California state court on a charge of kidnapping to commit robbery, rape, and murder, his confession was introduced in evidence. He was convicted, but on appeal the Supreme Court of California reversed, holding that the confession was not admissible because defendant should have been advised of his right to remain silent and of his right to counsel. (62 Cal 2d 571, 43 Cal Rptr 201, 400 P2d 97.) On certiorari, the Supreme Court of the United States affirmed on the ground that the Court would not presume that the defendant had been effectively apprised of his rights, on a record which did not show that any warnings had been given or that any effective alternative had been employed. Clark, J., concurred in the result. Harlan, Stewart, and White, JJ., dissented.

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