Brief This Case Miranda v. Arizona

Miranda v. Arizona. 384 U.S. 436 (1966)

This case was first brought in district court against Ernest Miranda after a rape investigation led authorities to question him. Under questioning, Miranda admitted to raping a young girl and signed a written confession. The case was heard in Phoenix district court and Miranda was adjudicated as guilty. The Arizona Supreme Court rejected Miranda's appeal, finding him guilty once again. The U.S. Supreme Court reversed.

Ernesto Miranda was accused of raping a young woman. The woman described her assailant and his vehicle, and using this information, the police traced the vehicle description to Miranda. Miranda also fit the physical description of the attacker, and was arrested and questioned. Under questioning, Miranda signed a written confession. His district trial summarily convicted him and he was sentenced to thirty to forty years in prison.

Miranda's lawyer appealed to the state supreme court on the grounds that his client was not aware that he was entitled to an attorney when he made his confession; the investigating officer had, in fact, testified that it was not standard to inform individuals under arrest of their rights before they made a statement. The Arizona Supreme Court rejected this reasoning and upheld Miranda's conviction. Miranda then appealed on the same basis -- that he was unaware of his right to counsel or against self-incrimination -- to the Supreme Court, which accepted the case.

The Supreme Court had ruled in a prior case about the right of arrested persons to counsel in Gideon v. Wainwright. 372 U.S. 335, (1963) This case established that an accused individual had the right to an attorney being present at their trial, but did not establish a right to an attorney at any other point. Miranda's counsel argued in both the district court and state Supreme Court that this opinion should be interpreted to mean that an accused person has a right to counsel throughout his interactions with police. Both courts rejected this interpretation.

During the time period between Miranda's district court conviction and his trial at the Arizona Supreme Court, the U.S. Supreme Court issued a rule that made it mandatory for suspects in custody to have access to counsel. Even pre-indictment, the Court ruled, suspects had the right to consult with their attorney. (Escobedo v. Illinois, 378 U.S. 478) Still, the Arizona Supreme Court did not believe that the lack of counsel present invalidated Miranda's confession.

The questions determined by the Supreme Court, which chose to hear Miranda's case in conjunction with three other, similar Fifth/Sixth Amendment cases, were concerned with what constituted a violation of these civil rights when questioning a suspect. More specifically, the Court was concerned with how law enforcement officials were ensuring that suspects were aware of their Fifth Amendment right to self-incrimination and their Sixth Amendment right to counsel.

The Court established that not only were the basic protections against self-incrimination and to counsel in all phases of interrogation valid, but that police could not assume that suspects automatically knew of these rights. The Court determined that in order to ensure all suspects were aware of these rights, police had to explain them aloud. Specifically, a suspect "must first be informed in clear and unequivocal terms that he has the right to remain silent (384 U.S. 436, 468). This explanation also must include "that anything said can and will be used against the individual in court." (384 U.S. 484, 470) With regards to counsel, suspects "must be clearly informed that he has the right to consult with a lawyer and to have the lawyer with him during interrogation." (384 U.S. 436, 472) Suspects must also have the fact explained that if they cannot afford an attorney, the state will provide one free of charge. (384 U.S. 436, 474)

The Court justified the requirement that these rights be explained because any time an individual is detained or questioned by authorities, "the privilege against self-incrimination is jeopardized." (384 U.S. 436, 479) The only verifiable method of providing that all suspects are aware of their rights is to regulate a reading of them before any interaction with law enforcement occurs. The court reversed Miranda's conviction because it was not clear that he was aware of his rights; just because he signed a statement claiming "that he had full knowledge of his legal rights does not approach the knowing and intelligent waiver required to relinquish constitutional rights." (384 U.S. 436, 493) Setting up the requisite "reading of the rights" would provide a more objective measure for ensuring that each suspect was aware of the remedies and rights available to him.

The Court rationalized this decision by explaining the FBI's procedure, which was standardized so that all suspects were made aware of their rights. The FBI procedure included that "both suspects and persons under arrest...ha[ve] a right to say nothing and a right to counsel, and that any statement he does make may be used against him in court." (384 U.S. 436, 485) The FBI also required that agents inform suspects of "his right to free counsel if he is unable to pay," and noted that the "warning is given to the suspect at the very outset of the interview." (384 U.S. 436, 486) When requiring that all law enforcement agencies inform suspects of these same rights, the Supreme Court saw no substantial burden in requiring the same behavior of state and local agencies. They also noted that "the argument that the FBI deals with different crimes than are dealt with by state authorities does not mitigate the significance [of the warnings]" (384 U.S. 436, 487) Any difference in crimes committed does not, as the Court correctly asserted, require a different treatment with regard to the Fifth and Sixth Amendment rights to counsel and against self-incrimination.