1.2: Case Brief Sample - Miranda v. Arizona
384 U.S. 436 (1966)
Court: United States Supreme Court.
Judicial History: Ernesto Miranda (D) was convicted for kidnapping, rape, and robbery by the Arizona criminal courts. D appealed to the Arizona Supreme Court but the conviction was sustained. The U.S. Supreme Court granted certiorari to determine the role police have in protecting the rights of the accused from issues arising in four different cases (Miranda v. Arizona; Vignera v. New York; Westover v. United Stated; and California v. Stewart).
Facts: D was a Mexican immigrant living in Phoenix, AZ. D had a history of mental instability and was a 9th grade drop out. D was identified as a suspect in the kidnapping and rape of an 18 year old girl. D was arrested by the Phoenix Police Department at his home and taken to the police station for questioning. D was not advised of his Constitutional guarantees of self-incrimination or to have attorney present. After two hours of police interrogation, D confessed to the crimes. D was convicted and sentenced concurrently to twenty years each. D appealed to the Arizona Supreme Court citing that his confession was not truly voluntary but the AZ Supreme Court sustained the conviction.
Issue: During custodial interrogation and before questioning, must the police (1) inform a suspect that he has a right to remain silent (2) warn him that any statements he makes may be used against him and (3) advise him that he has a right to an attorney?
Holding: Yes. Law enforcement officers must inform a person of his rights when that person is in custody and subject to an interrogation. Any incriminating statements obtained in violation of these rights are inadmissible at trial.
Reasoning: The Supreme Court scrutinized coercive conditions in which police were obtaining and introducing incriminating admissions obtained during police questioning which was in conflict with one of the Nation’s most cherished principlesthe right against self-incrimination. In order to preserve Constitutional protections guaranteed by the 5th and 6th Amendments, the Court ruled that these protections would be extended from criminal trials to custodial interrogations. Statements or confessions would not be made admissible at trial unless a suspect was informed that (1) he has a right to remain silent (2) anything he says will be used against him in court (3) he has the right to consult with a lawyer and to have that lawyer present during questioning and (4) if he cannot afford and attorney, one will be appointed to him by the court.
Decision: 5-4. Miranda’s conviction overturned and remanded back to state court.
Opinion: Chief Justice Warren, joined by Justices Black, Douglas, Brennan, and Fortas.
Dissenting Opinions: Written by Chief Justice Harlan and joined by Justices Stewart and White. These new rules do not discourage police brutality or coercion but rather negate police pressures and ultimately discourage any suspect confessions at all. Furthermore, the new rules do not discourage any officers already predisposed to corrupt practices. The court is taking a real risk with society’s welfare as it relates to crime control and engaging in hazardous experimentation.
Dissenting in Part Opinion: Written by Justice White. There is no support in the history of the protection to support the majority findings. Furthermore, the language does not allow for such a basis in common law.
Follow-Up
After Miranda’s conviction was overturned, the state court retired him. Miranda’s confession was not introduced into evidence. The prosecution relied on witness testimony and Miranda was again convicted and sentenced to 20-30 years in prison.