Case Summary : Ernest A. Miranda v. The State of Arizona
Cases Referred: Westover v. United States; Vignera v. State of New York; State of California v. Stewart.
Citation: 384 U.S. 436 (1966).
Name of Court: Arizona’s Maricopa County Superior Court, Supreme Court of Arizona, Supreme Court of United States.
Name of Judges: Chief Justice Earl Warren, Justice Hugo Black, Justice Douglas, Justice Clark, Justice Harlan, Justice Brennan, Justice Stewart, Justice White, Justice Fortas.
Name of Parties : Ernesto Miranda & State of Arizona
Miranda Vs Arizona, 1966 is a consolidation of four cases tried in the United States Supreme Court, the decision of the Court on the issue of rights under Fifth amendment is regarded as a landmark judgement of its time, it is by far the most cited case in American Criminal Proceedings History.
In early March 1963, an eighteen year old woman, Jane Doe was raped and kidnapped and this was reported in to the Phoenix Police Department in Arizona. A police line-up of identification took place and a witness recognised Ernesto Miranda who was previously arrested for similar charges. On March 13, Miranda was interrogated heavily by police and detectives in the ‘Special Interrogation Room’. The detectives did not go rough on Miranda, neither did they promise him leniency. Miranda later briefly confessed to rape and kidnapping and even admitted to Ms. Doe being the victim. He was later asked to give his confession in writing. Across that confession letter, on top, was an already typed disclaimer “ I am confessing voluntarily, without treats or promises of immunity, with full knowledge of my legal rights, understanding any statement I make may be used against me.” He signed the confession with the aforementioned part. The district attorney soon filed a case against Miranda and it was tried by a jury in Arizona’s Maricopa County Superior Court.
Judgement of Arizona’s Maricopa County Superior Court
It held that Miranda was guilty for both the crimes that he was accused of. Moore, his counsel objected that the confession should be excluded because he was not advised of his right to remain silent. The objections were overruled.
Judgement of Supreme Court of Arizona
Further it was appealed to Supreme Court of Arizona which upheld the ruling of the trial court with a punishment of imprisonment of 20-30 years and even stated that Miranda’s constitutional rights were not violated.
Moore, did not stop at this, he appealed to the United States Supreme Court, where John Paul Frank represented Miranda.
The only issues that was before the United States Supreme Court, which could help reverse the judgement of lower courts were-
“Whether the statements obtained from an individual who is subjected to custodial police investigation” are admissible in a criminal trial and was Miranda’s Fifth Amendment privilege against self incrimination was violated because police failed to inform him
• His right to remain silent
• His right to consult an attorney
The Fifth Amendment of the United States Constitution guarantees different constitutional rights like right to indictment by Grand Jury, double jeopardy, right against self incrimination etc. This amendment protects criminal defendants from having to testify if they may incriminate themselves through the testimony.
The Sixth Amendment gives protection to criminal defendants ‘right’ to have assistance of a counsel.
The Fifth and Sixth amendments of the United States Constitution definitely gave right to Miranda to protect himself against self incrimination and to have assistance of a counsel. But these rights were waived as soon as Miranda signed the confession post the interrogation. It was even claimed through the obtained testimonies in the proceedings that Miranda was not unaware of police procedures and neither was he stranger to his constitutional rights. It was also proved that he tried negotiating with the officials. And most importantly he signed his confession ‘willingly’. The prosecution urged the Supreme Court to uphold his conviction because Miranda’s prosecution was without any glitch, his conviction was followed by the provisions of Arizona Law and his imprisonment was justified. Also, the prosecution contested on the point that in case where the Court allows accused to plead ‘The Fifth’ outside Court proceedings, almost every criminal will have an unfettered facility to not incriminate against himself/ herself thus making the police interrogations of no use and absolutely difficult to even conduct.
The Defense claimed that the police officials by straightaway allowing detectives to question Miranda for two long hours without an attorney and without prior warnings of his constitutional rights clearly violated his ‘right to remain silent’, and his ‘right to legal counsel’. The oral arguments from proceedings show how the police officials obstructed Miranda’s counsel from entering the interrogation room, the State of Arizona ignored both
1)The Escobedo rule (Escobedo Vs Illinois, 1964) – It states that the evidence obtained from an illegally obtained confession is not admissible in court
2) The Gideon rule (Gideon Vs Wainwright, 1963) – It states that all felony defendants have the right to an attorney.
The defense argued that Miranda’s confession was illegally obtained as he was not made aware or was not reminded of his rights, he should be excluded from the record and also made inadmissible in Courts of Law and then a new trial to prosecute him should be conducted.
“You have the right to remain silent. Anything you say can and will be used against you in a court of law. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you. Do you understand the rights I have just read to you? With these rights in mind, do you wish to speak to me?”
The Majority Opinion
Chief Justice Earl Warren gave the majority decision of the Court, the Court held that Miranda’s confession was not admissible in Courts of Law and is mandatory to be excluded. The reasoning behind this ruling was ‘no effective advisement given to Miranda to remind him of his Constitutional rights to remain silent and be assisted by an attorney. The Warren Court explained how police interrogations are often coercive, extremely harsh and torturous for the accused. So much so that ‘third degree’ is often used as a slang for such custodial interrogations. Warren even incorporated various police interrogation manuals in the judgement for a better understanding. The court held only after the accused is made aware of his rights under Fifth and Sixth Amendment and these rights are voluntarily waived, an obtained confession would be admissible and legal. It was also made clear that in case the accused at any point wishes to exercise his rights to remain silent, the interrogation shall cease, if he wishes to not answer in the absence of an attorney, the interrogation shall cease.
In order to understand why such relaxation was implemented for custodial interrogations, the Wickersham Report to Congress by a Presidential Commission should be analysed it clearly depicts how the police violence and the “third degree” flourished at that point of time.
Concurring Opinion of Justice Clark
He both concurred and dissented from the majority opinion. Justice Clark believed that a hard and fast rule under the Fifth Amendment should not be made rather the courts should analyse each case to decide if the state, before interrogation, had warned the defendant of his rights. Now if such warnings were not given, Justice Clark believed that totality of circumstances should again be observed rather than completely declaring the confession as inadmissible.
Two dissenting judges Justice Harlan and Justice White gave the minority opinion. Both accused the majority judgement of rather improper judicial activism.. Both of them also questioned the majority’s use of the Fifth Amendment’s clause to be applied as the standard. Again, the line rule of that historic judgement would produce would definitely reduce but not exhaust the coercive tactics of state to obtain confessions, and in any case then, a thorough interrogative investigation would also be required. Finally, Justice White also expressed his concern that the majority’s decision would most probably rather damage the ability of police to do effective work because more defendants (especially the intelligent ones) would be less likely to make confessions. This would reduce the amount of confessions, lose the essence of interrogations in our judicial system and also increase the number of trials because then only trials would be definite way of proving the allegations.
Almost 55 years ago, this landmark judgement was given, not only did it change the structure of custodial interrogation but it also dynamically altered the American Criminal Proceeding Procedure.
This historical judgement laid down the ‘Miranda Warnings’, these warnings were essentially a reminder to the accused before interrogations that his/her rights to remain silent and have an attorney are protected by law, not only were these applicable inside the court but also outside during custodial interrogations, even if at any point during the interrogation the accused wanted to exercise his rights, he could. These Miranda Rights are read by officials while arresting people till date in the United States. We often observe them while watching Hollywood movies, These are as follows:-
“You have the right to remain silent, if you do say anything, it can be used against you in a court of law. You have the right to have a lawyer present during any questioning. If you cannot afford a lawyer, one will be appointed for you if you so desire.” If the officials fail to give these warnings, anything that the arrestee may have responded during questioning shall not be admissible in the form of evidence.
Unfortunately after Ernesto Miranda was released in 1976, he was stabbed to death during a bar fight. The suspected killer was read his Miranda rights, which he intelligently exercised and refrained from answering questions to the police. He was not proved guilty for Miranda’s death. There was no conviction at all in his murder trial.
Reference: Read the proceedings and oral arguments here