Quick Summary
Ernesto Miranda (defendant) was convicted after a confession obtained during a police interrogation without being informed of his Fifth Amendment rights.
The main issue was the admissibility of confessions obtained without informing defendants of their Fifth and Sixth Amendment rights.
The Supreme Court concluded that such confessions are inadmissible, overturning Miranda’s conviction based on constitutional grounds.
Rule of Law
Statements made by an individual in police custody will be admissible in court only if the individual was informed of their rights to remain silent and to have an attorney present, and if these rights were waived in a knowing, voluntary, and intelligent manner.
Facts of the Case
The Supreme Court merged four different cases into this single case.
- In the first case, Ernesto Miranda was arrested for robbery, rape and abduction. He wasn’t told he had a right to an attorney or remain silent when he was brought in for questioning. He admitted his guilt and was found guilty.
- In the second case, Michael Vignera was arrested for robbery. Mr. Vignera confessed his crimes after arrest but no evidence indicates he was informed of his Fifth Amendment rights.
- In the third case, Carl Calvin Westover was arrested for two robberies. Local police interrogated Mr. Westover and obtained written confessions. Mr. Westover wasn’t told his Fifth Amendment rights.
- In the fourth case, Roy Allen Stewart (also known as “Mr. Stewart”) and his family were arrested in a handbag theft case. Same in other cases, Mr. Stewart confessed his crimes but wasn’t told his Fifth Amendment rights.
The Supreme Court accepted these four cases to study the questioning procedures needed to defend the Fifth Amendment right not to be coerced to testify against oneself.
Issue
Is interrogation evidence admissible if it is obtained before the suspect is informed of their Fifth Amendment rights?
Holding and Conclusion
No. Interrogation evidence cannot be used against a defendant unless the prosecution can establish the detainee was warned and waived them consciously and reasonably.
The Court established several procedural safeguards to protect individuals’ constitutional rights during police interrogations:
- Right to Remain Silent: Suspects must be informed of their right to remain silent before interrogation begins.
- Right to Counsel: Suspects must be informed of their right to consult with an attorney and to have an attorney present during questioning.
- Waiver of Rights: If a suspect chooses to waive these rights, the waiver must be voluntary, knowing, and intelligent.
- Exclusionary Rule: Confessions obtained in violation of these rights are inadmissible as evidence in court.
Reasoning and Analysis
Many rights relevant to both criminal and civil proceedings are established under the Fifth Amendment. The Fifth Amendment guarantees the right to trial by jury in criminal cases, prohibits double jeopardy, and protects individuals from self-incrimination.
Without this, interrogation statements are not admissible in court. It protects both innocent and criminal persons who find themselves in vulnerable situations.
A lengthy exposition of the right against self-incrimination led to the court’s decision that the privilege of this right must be honored throughout the questioning process unless the individual voluntarily, knowingly, and intellectually waives this privilege.
The Supreme Court concluded that it did not want its rules to become an obstacle to effective law enforcement. If neither the states nor the federal government takes action to alter the system, it states that the above procedures must be fulfilled within the established system. As long as it is conducted in accordance with the court’s guidelines, a question-and-answer session can result in a statement that could be used as evidence in court.
Relevant FAQs of this case
What are Miranda rights?
The Supreme Court’s ruling in this case, which established the Miranda rule as a constitutional right, mandates that suspects be informed of their Fifth and Sixth Amendment rights “before any interrogation” if their statements are to be used as evidence in a court of law.
Who won this case?
Ernesto Miranda won this case as Supreme Court determined that Miranda’s initial confession was invalid and granted him a second trial. However, based on additional evidence, he was found guilty of kidnapping and rape, and he served 11 years in prison until being paroled in 1972.
References
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