Miranda Vs Arizona
Miranda Vs Arizona
Miranda Vs Arizona
Arizona
384 U.S. 436
Argued: Feb. 28, March 1 and 2, 1966 | Decided: June 13, 1966
Warren, C.J.
The Fifth Amendment privilege against self-incrimination requires law
enforcement officials to advise a suspect interrogated in custody of his rights
to remain silent and to obtain an attorney. Arizona Supreme Court reversed
and remanded.
The Supreme Courts decision in Miranda v. Arizona addressed four different
cases involving custodial interrogations. In each of these cases, the
defendant was questioned by police officers, detectives, or a prosecuting
attorney in a room in which he was cut off from the outside world. In none of
these cases was the defendant given a full and effective warning of his rights
at the outset of the interrogation process. In all the cases, the questioning
elicited oral admissions and, in three of them, signed statements that were
admitted at trial.
Miranda v. Arizona: Miranda was arrested at his home and taken in custody
to a police station where he was identified by the complaining witness. He
was then interrogated by two police officers for two hours, which resulted in
a signed, written confession. At trial, the oral and written confessions were
presented to the jury. Miranda was found guilty of kidnapping and rape and
was sentenced to 20-30 years imprisonment on each count. On appeal, the
Supreme Court of Arizona held that Mirandas constitutional rights were not
violated in obtaining the confession.
Vignera v. New York: Vignera was picked up by New York police in connection
with the robbery of a dress shop that had occurred three days prior. He was
first taken to the 17th Detective Squad headquarters. He was then taken to
the 66th Detective Squad, where he orally admitted the robbery and was
placed under formal arrest. He was then taken to the 70th Precinct for
detention, where he was questioned by an assistant district attorney in the
presence of a hearing reporter who transcribed the questions and answers.
At trial, the oral confession and the transcript were presented to the jury.
Vignera was found guilty of first degree robbery and sentenced to 30-60
years imprisonment. The conviction was affirmed without opinion by the
Appellate Division and the Court of Appeals.
Westover v. United States: Westover was arrested by local police in Kansas
City as a suspect in two Kansas City robberies and taken to a local police
station. A report was also received from the FBI that Westover was wanted
on a felony charge in California. Westover was interrogated the night of the
arrest and the next morning by local police. Then, FBI agents continued the
interrogation at the station. After two-and-a-half hours of interrogation by the
FBI, Westover signed separate confessions, which had been prepared by one
of the agents during the interrogation, to each of the two robberies in
California. These statements were introduced at trial. Westover was
convicted of the California robberies and sentenced to 15 years
imprisonment on each count. The conviction was affirmed by the Court of
Appeals for the Ninth Circuit.
California v. Stewart: In the course of investigating a series of purse-snatch
robberies in which one of the victims died of injuries inflicted by her
assailant, Stewart was identified as the endorser of checks stolen in one of
the robberies. Steward was arrested at his home. Police also arrested
Stewarts wife and three other people who were visiting him. Stewart was
placed in a cell, and, over the next five days, was interrogated on nine
different occasions. During the ninth interrogation session, Stewart stated
that he had robbed the deceased, but had not meant to hurt her. At that
time, police released the four other people arrested with Stewart because
there was no evidence to connect any of them with the crime. At trial,
Stewarts statements were introduced. Stewart was convicted of robbery and
first-degree murder and sentenced to death. The Supreme Court of California
reversed, holding that Stewart should have been advised of his right to
remain silent and his right to counsel.
Issues:
Whether statements obtained from an individual who is subjected to
custodial police interrogation are admissible against him in a criminal trial
and whether procedures which assure that the individual is accorded his
privilege under the Fifth Amendment to the Constitution not to be compelled
to incriminate himself are necessary.
Held:
The Court held that there can be no doubt that the Fifth Amendment
privilege is available outside of criminal court proceedings and serves to
protect persons in all settings in which their freedom of action is curtailed in
any significant way from being compelled to incriminate themselves. As
such, the prosecution may not use statements, whether exculpatory or
inculpatory, stemming from custodial interrogation of the defendant unless it
demonstrates the use of procedural safeguards effective to secure the
privilege against self-incrimination. By custodial interrogation, we mean
questioning initiated by law enforcement officers after a person has been
taken into custody or otherwise deprived of his freedom of action in any
significant way.
The Court further held that without proper safeguards the process of incustody interrogation of persons suspected or accused of crime contains
inherently compelling pressures which work to undermine the individuals will
to resist and to compel him to speak where he would otherwise do so freely.