The Oyez Project: Criminal Procedure Issues - Miranda Warnings Decisions

Arizona v. Mauro

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Arizona v. Roberson

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Beckwith v. United States

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Berkemer v. Mccarty

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Colorado v. Connelly

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Connecticut v. Barrett

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Davis v. United States

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Dickerson v. United States

May Congress legislatively overrule Miranda v. Arizona and its warnings that govern the admissibility of statements made during custodial interrogation?

No. In a 7-2 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Miranda governs the admissibility of statements made during custodial interrogation in both state and federal courts. "Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture," wrote Rehnquist. "Miranda announced a constitutional rule that Congress may not supersede legislatively. We decline to overrule Miranda ourselves," concluded the Chief Justice. Dissenting, Justice Antonin Scalia, joined by Justice Clarence Thomas, blasted the Court's ruling, writing that the majority opinion gave needless protection to "foolish (but not compelled) confessions."

Doyle v. Ohio

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Duckworth v. Eagan

Did the first warning and waiver negate the constitutional protections required by Miranda v. Arizona?

In a closely divided decision, the Court held that informing Eagan that an attorney would be appointed for him "if and when you go to court" did not render the Miranda warnings inadequate. The Court reasoned that officers did not have to use the specific language of the Miranda decision so long as they reasonably conveyed to suspects their constitutional rights. Chief Justice Rehnquist argued that the instructions given to Eagan accurately described the procedure for the appointment of counsel in Indiana.

Edwards v. Arizona

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Fare v. Michael C.

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Greer v. Miller

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Harris v. New York

Did the use of Harris' post-arrest statement violate his Fifth, Sixth, and Fourteenth Amendment rights guaranteed by the Miranda decision?

No. In a 5-to-4 decision, the Court held that the Miranda decision did not mandate that evidence inadmissible against an accused in the prosecution's case must be barred for all purposes from the trial. The Court reasoned that the shield provided by Miranda could not be "perverted into a license to use perjury by way of a defense, free from the risk of confrontation with prior inconsistent utterances." The Court found that the speculative possibility that police misconduct could be encouraged was outweighed by the value of admitting the statement into the impeachment process.

Illinois v. Perkins

Did the undercover police officer violate the accused's Miranda rights as protected by the Fifth and Fourteenth Amendments?

The Court held that conversations between suspects and undercover officers are not afforded Miranda protection since they are not done in a "police-dominated atmosphere" where compulsion to confess is present. "It is the premise of Miranda that the danger of coercion results from the interaction of custody and official interrogation," argued Justice Kennedy. There was no danger of coercion in this case.

Mathis v. United States

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Michigan v. Mosley

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Michigan v. Tucker

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Minnick v. Mississippi

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Miranda v. Arizona

Does the police practice of interrogating individuals without notifiying them of their right to counsel and their protection against self-incrimination violate the Fifth Amendment?

The Court held that prosecutors could not use statements stemming from custodial interrogation of defendants unless they demonstrated the use of procedural safeguards "effective to secure the privilege against self-incrimination." The Court noted that "the modern practice of in-custody interrogation is psychologically rather than physically oriented" and that "the blood of the accused is not the only hallmark of an unconstitutional inquisition." The Court specifically outlined the necessary aspects of police warnings to suspects, including warnings of the right to remain silent and the right to have counsel present during interrogations.

Missouri v. Seibert

Does the rule from Oregon v. Elstad that a defendant who has made an un-Mirandized confession may later waive her Miranda rights to make a second confession (admissible in court) still apply when the initial confession is the result of an intentional decision by a police officer to withhold her Miranda warnings?

No. In a decision with no majority, a four-justice plurality found that the post-Miranda confession is only admissible - even if the two-stage interview was unintentional, as it was in Elstad - if the Miranda warning and accompanying break are sufficient to give the suspect the reasonable belief that she has the right not to speak with the police. Justice Anthony Kennedy, in a concurring opinion that provided the fifth vote, found that evaluating the warning and accompanying break was only necessary if the police used the two-stage interrogation intentionally. Justice Kennedy wrote, "The admissibility of postwarning statements should continue to be governed by Elstad's principles unless the deliberate two-step strategy is employed. Then, the postwarning statements must be excluded unless curative measures are taken before they were made."

Moran v. Burbine

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New York v. Quarles

Should the Court suppress Quarles's statement about the gun and the gun itself because the officer had failed at the time to read Quarles his Miranda rights?

No. The Court held that there is a "public safety" exception to the requirement that officers issue Miranda warnings to suspects. Since the police officer's request for the location of the gun was prompted by an immediate interest in assuring that it did not injure an innocent bystander or fall into the hands of a potential accomplice to Quarles, his failure to read the Miranda warning did not violate the Constitution.

North Carolina v. Butler

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Oregon v. Bradshaw

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Oregon v. Elstad

Was Elstad's written confession made invalid by the failure of the officers to administer Miranda warnings at his home?

In a 6-to-3 decision, the Court held that while Miranda required that unwarned admissions must be suppressed, subsequent statements, if made knowingly and voluntarily, need not be. The Court held that ". . .the mere fact that a suspect has made an unwarned admission does not warrant a presumption of compulsion." The Court also noted that police officers were ill-equipped to determine when "custody" legally begins. Justice O'Connor, writing for the majority, argued that the holding "in no way retreat[ed] from the bright-line rule of Miranda."

Oregon v. Hass

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Orozco v. Texas

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Pennsylvania v. Muniz

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Rhode Island v. Innis

Did the police "interrogation" en route to the station violate Innis's Miranda rights?

No. In a 6-to-3 decision, the Court held that the Miranda safeguards came into play "whenever a person in custody is subjected to either express questioning or its functional equivalent," noting that the term "interrogation" under Miranda included "any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the subject." The Court then found that the officers' conversation did not qualify as words or actions that they should have known were reasonably likely to elicit such a response from Innis.

Stansbury v. California

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United States v. Hale

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United States v. Mandujano

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United States v. Patane

Can physical evidence found as a result of un-Mirandized but voluntary testimony be used in court?

Yes. In a decision without a majority opinion, three justices wrote that the Miranda warnings were merely intended to prevent violations of the Constitution, and that because Patane's un-Mirandized testimony was not admitted at trial the Constitution (specifically the Fifth Amendment's protection against self-incrimination) had not been violated. Physical evidence obtained from un-Mirandized statements, as long as those statement were not forced by police, were constitutionally admissible. Two other justices also held that the physical evidence was constitutionally admissible, but did so with the understanding that the Miranda warnings must be accommodated to other objectives of the criminal justice system. They did not discuss whether the Miranda warnings were, in themselves, constitutionally required.

Yarborough v. Alvarado

When deciding whether a suspect is "in custody" and therefore entitled to his Miranda warnings, must an officer consider the suspect's age and previous history with law enforcement?

No. In a 5-to-4 decision written by Justice Anthony Kennedy, the Court ruled that the purpose of the Court's Miranda decision was to provide an objective rule readily understandable by police officers: when interrogating a suspect who is "in custody," an officer must first read the suspect his Miranda rights. Determining whether a suspect is actually in custody has always been based on objective criterion like whether he had been brought to the police station by police or had come of his own accord. Requiring officers to consider individual characteristics of a suspect when determining whether he is "in custody," such as the suspect's age or previous history with law enforcement, would make the test a subjective one that would be more difficult for officers to understand and abide by. Justice Kennedy wrote that the Miranda decision "states an objective rule designed to give clear guidance to the police, while consideration of a suspect's individual characteristics - including his age - could be viewed as creating a subjective inquiry."