Miranda v. Arizona: Due Process, Rights & Legal Impact

Background of Miranda v. Arizona

With its foundational roots in the 1961 Mapp v. Ohio case, the 1963 Gideon v. Wainwright case, and the 1964 Escobedo v. Illinois case, the U.S. Supreme Court under Chief Justice Warren handed down its standard of "fundamental fairness" in Miranda v. Arizona. At both federal and state levels, the Court sent an explicit signal to criminal justice and law enforcement officials: verdicts that did not conform to this "fairness" standard were likely to be overturned. Maintenance of the due process guaranteed for accused parties was considered essential (Miranda v. Arizona, 1966).

Together with Miranda, several other similar cases were heard by the Supreme Court, but because this case appears at the forefront of the docket, the collective judgment of the Court is known by the name Miranda. The Court's decision distilled the numerous standards of "fundamental fairness" into a single concise statement of accused parties' rights to due process. The warning provided by Miranda has since developed into a familiar statement of citizens' rights, well known to the public largely through television police dramas.

In March of 1963, a sexual assault and kidnapping took place in Phoenix, Arizona. On March 13, 23-year-old Ernesto Miranda was arrested at his home, driven to a police station where the victim identified him, and then taken in for interrogation. He was not informed of his right to counsel before being questioned (Miranda v. Arizona, 1966). After several hours of interrogation, law enforcement investigators left the room with a written and signed confession, including a typed disclaimer in which Miranda stated that he was fully aware of his legal rights, understood that his statements could be used against him in court, and had knowingly relinquished those rights.

At his first hearing, held a few weeks later, Miranda was again denied counsel. Although he was represented by a lawyer at trial, that lawyer's objection to admitting the signed confession as evidence was overruled. Miranda was found guilty of kidnapping and rape and received a prison sentence of twenty years. Nevertheless, the case raised critical issues pertaining to civil liberties, and it is for this reason that it remains one of the most studied decisions in American constitutional law.

The Court's Opinion

The Court held that prosecutors may not use inculpatory or exculpatory statements obtained through custodial questioning — that is, questioning initiated by law enforcement after an individual has been apprehended or otherwise deprived of freedom of action in any significant way — unless they demonstrate that procedural protections were applied that successfully secured the suspect's Fifth Amendment privilege against self-incrimination. The conditions of modern incommunicado interrogation are inherently coercive and serve to undermine this privilege. Unless adequate preventive measures are taken to dispel the compulsion characteristic of custodial settings, a defendant's statements cannot truly be considered the product of his or her free will (Miranda v. Arizona: 384 U.S. 436, 1966).

The constitutional privilege against compelled self-incrimination — a protection with a lengthy history — is a critical pillar of the nation's adversarial legal system. It guarantees individuals the right to remain silent unless they choose to speak of their own free will, throughout custodial interrogations, court trials, and other authorized investigations. In the absence of other adequate protective measures, the following procedural safeguards must be observed:

Before interrogation begins, suspects must be clearly informed that they have the right to remain silent, and that anything they say may be used against them at trial. They must also be told that they have the right to consult with an attorney, and that their attorney may be present during interrogation. Finally, if a suspect cannot afford to hire a private attorney, one will be appointed to represent them.

References

Beatty, G. (1999). The allegory of the cave: Statistical studies of the impact of the Miranda decision on law enforcement. The Federalist Society. Retrieved June 10, 2016, from http://www.fed-soc.org/publications/detail/the-allegory-of-the-cave-statistical-studies-of-the-impact-of-the-miranda-decision-on-law-enforcement

Casebriefs. (n.d.). Miranda v. Arizona — Casebriefs, Part 2. Retrieved June 10, 2016, from http://www.casebriefs.com/blog/law/criminal-procedure/criminal-procedure-keyed-to-israel/police-interrogation-and-confessions/miranda-v-arizona-2/2/

FindLaw. (n.d.). MIRANDA v. ARIZONA. Retrieved June 10, 2016, from http://caselaw.findlaw.com/us-supreme-court/384/436.html

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Inbau, F., & Manak, J. (1987). Miranda v. Arizona — Is it worth the cost? A sample survey, with commentary, of the expenditure of court time and effort. California Western Law Review, 24(1). Retrieved June 9, 2016, from http://scholarlycommons.law.cwsl.edu/cgi/viewcontent.cgi?article=1486&context=cwlr

Miranda v. Arizona (1966). (n.d.). Infoplease. Retrieved June 9, 2016, from http://www.infoplease.com/us/supreme-court/cases/ar23.html

Miranda v. Arizona: 384 U.S. 436 (1966). (n.d.). Justia U.S. Supreme Court Center. Retrieved June 9, 2016, from http://supreme.justia.com/cases/federal/us/384/436/

McBride, A. (n.d.). Miranda v. Arizona (1966). PBS: The Supreme Court — Expanding Civil Rights, Landmark Cases. Retrieved June 10, 2016, from http://www.pbs.org/wnet/supremecourt/rights/landmark_miranda.html

Miranda Rights. (n.d.). Self-incrimination. Retrieved June 10, 2016, from

The Patriot Post. (n.d.). Miranda v. Arizona. Retrieved June 10, 2016, from http://patriotpost.us/documents/252