The Oyez Project: Criminal Procedure Issues - Miranda Warnings

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

During questioning about a robbery he was connected to, Charles Dickerson made statements to authorities admitting that he was the getaway driver in a series of bank robberies. Dickerson was then placed under arrest. The timing of his statement is disputed. The FBI and local detectives testified that Dickerson was advised of his Miranda rights, established in Miranda v. Arizona, and waived them before he made his statement. Dickerson said he was not read his Miranda warnings until after he gave his statement. After his indictment for bank robbery, Dickerson filed a motion to suppress the statement that he made on the ground that he had not received Miranda warnings before being interrogated. The government argued that even if the Miranda warnings were not read, the statement was voluntary and therefore admissible under 18 USC Section 3501, which provides that "a confession shall be admissible in evidence if it is voluntarily given." The District Court granted Dickerson's motion, finding that he had not been read his Miranda rights or signed a waiver until after he made his statement, but the court did not address section 3501. In reversing, the Court of Appeals acknowledged that Dickerson had not received Miranda warnings, but held that section 3501 was satisfied because his statement was voluntary. The court held that "Congress enacted section 3501 with the express purpose of legislatively overruling Miranda and restoring voluntariness as the test for admitting confessions in federal court."

Doyle v. Ohio

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Duckworth v. Eagan

When first questioned by police about the stabbing of a woman, suspect Gary Eagan did not make incriminating statements after signing a waiver and being told he would be provided a lawyer "if and when you go to court." The following day, after Eagan was questioned again and signed a different waiver, he confessed to the stabbing and revealed physical evidence of the crime. Eagan later claimed that the language of the first waiver made his confession inadmissible.

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

Harris was arrested for making two sales of heroin to an undercover police officer. Before receiving the Miranda warnings, Harris said that he had made both sales at the request of the officer. This statement was not admitted into evidence at the trial. However, Harris later testified in Court that he did not make the first sale and in the second sale he merely sold the officer baking powder. Harris' initial statement was then used by the prosecution in an attempt to impeach his credibility.

Illinois v. Perkins

While being held in jail, Perkins freely confessed to committing a murder to an undercover police officer who was posing as another inmate.

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

The Court was called upon to consider the constitutionality of a number of instances, ruled on jointly, in which defendants were questioned "while in custody or otherwise deprived of [their] freedom in any significant way." In Vignera v. New York, the petitioner was questioned by police, made oral admissions, and signed an inculpatory statement all without being notified of his right to counsel. Similarly, in Westover v. United States, the petitioner was arrested by the FBI, interrogated, and made to sign statements without being notified of his right to counsel. Lastly, in California v. Stewart, local police held and interrogated the defendant for five days without notification of his right to counsel. In all these cases, suspects were questioned by police officers, detectives, or prosecuting attorneys in rooms that cut them off from the outside world. In none of the cases were suspects given warnings of their rights at the outset of their interrogation.

Missouri v. Seibert

Patrice Seibert was convicted of second degree murder for the death of 17-year-old Donald Rector, who died in a fire set in the mobile home where he lived with Seibert. Several days after the fire, Seibert was interogated by a police officer. The officer initially withheld her Miranda warnings, hoping to get a confession from her first. Once she had confessed, the officer took a short break from questioning, then read her her Miranda rights and resumed questioning her after she waived those rights. He prompted her to restate the confession that she had made earlier. Based on this second, Mirandized confession, Seibert was convicted.

She appealed, charging that the officer's intentional use of an un-Mirandized interrogation to get the initial confession made the later confession, though it occurred after she had waived her Miranda rights, inadmissable. The prosecution cited Oregon v. Elstad to argue that an initial, un-Mirandized confession did not make a defendant incapable of voluntarily waiving her Miranda rights and confessing later.

The Supreme Court of Missouri agreed with Seibert, overturning the conviction.

Moran v. Burbine

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New York v. Quarles

After receiving the description of Quarles, an alleged assailant, a police officer entered a supermarket, spotted him, and ordered him to stop. Quarles stopped and was frisked by the officer. Upon detecting an empty shoulder holster, the officer asked Quarles where his gun was. Quarles responded. The officer then formally arrested Quarles and read him his Miranda rights.

North Carolina v. Butler

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Oregon v. Bradshaw

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Oregon v. Elstad

Michael James Elstad was suspected of committing a burglary and was picked up by police officers in his home. Before officers had given the warnings required by Miranda v. Arizona, Elstad made an incriminating statement. Once at the Sheriff's headquarters, Elstad was advised of his rights. Elstad then voluntarily executed a written confession.

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

After a picture identification by the victim of a robbery, Thomas J. Innis was arrested by police in Providence, Rhode Island. Innis was unarmed when arrested. Innis was advised of his Miranda rights and subsequently requested to speak with a lawyer. While escorting Innis to the station in a police car, three officers began discussing the shotgun involved in the robbery. One of the officers commented that there was a school for handicapped children in the area and that if one of the students found the weapon he might injure himself. Innis then interrupted and told the officers to turn the car around so he could show them where the gun was located.

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

Samuel Patane was arrested at his home for calling his ex-girlfriend in violation of a restraining order. During the arrest, police offers began reading Patane his Miranda rights. Patane told the officers that he knew his rights. The officers then stopped reading them, at which point Patane told police that he had a gun in his house. They searched the house with his permission and found the gun. As an ex-felon, Patane was not permitted to possess a gun and was prosecuted for possession.

During the trial on gun possession charges, Patane argued that his arrest violated the Fourth Amendment prohibition of unreasonable searches and seizures and the Fifth Amendment right not to incriminate oneself because there was not probable cause to arrest him and because the gun had been found as a result of an un-Mirandized confession.

The district court initially ruled that there was not probable cause for his arrest and that it was therefore unconstitutional. A 10th Circuit Court of Appeals panel disagreed, holding that Patane's ex-girlfriend had given police probable cause for the arrest. However, the panel held that gun could not be used as evidence because it had been found as the result of an un-Mirandized (and therefore unconstitutional) confession. The government appealed, arguing that physical evidence found as the result of un-Mirandized testimony could be used in court, despite the fact that the testimony itself was inadmissable.

Yarborough v. Alvarado

Police interviewed Michael Alvarado, 17, without his parents at a police station about his involvement in a crime. Police neither arrested nor Mirandized Alvarado. During the interview, Alvarado confessed involvement. Based, in part, on these statements, Alvarado was convicted of second-degree murder and attempted robbery. After failed appeals in the California courts, Alvarado unsuccessfully sought a writ of habeas corpus in federal district court in California. The Ninth Circuit Court of Appeals reversed. Recognizing the "in custody" standard to be whether a reasonable person would feel free to end interrogation, the appeals court held that a juvenile is more likely to feel he is in custody. Because Alvarado was "in custody," the Fifth Amendment required that his rights under Miranda v. Arizona (1966) be read to him.