Monday, June 06, 2005

 

Case Brief: Miranda v. Arizona, 384 U.S. 436 (1966)

Here's another case brief that should make the lives of law school students and CJ students a whole lot easier. Please do not copy this verbatim. Instead, use it as reference for writing your own case brief. Sometimes the issues of older cases are hard to grasp compared to the varied legal issues surrounding the cases we work on today, which is the only reason I post my own briefs.

Name of the Case

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

Facts of the Case

A defendant, Ernesto Miranda, was taken into custody and taken to a station house and put into "Interrogation Room No. 2," after being accused of a combination rape and kidnapping. Upon being interrogated by two officers, a written confession was obtained by the officers after two hours, although Miranda was never made aware of his basic rights. At the top of the confession sheet, it was typed that the confession was made voluntarily, "without threats or promises of immunity and 'with full knowledge of my legal rights, understanding any statement I make may be used against me'."

Issue

The issue at hand is whether or not the prosecution may use statements in the form of confessions given by a suspect when the suspect has not been advised of his basic rights against self-incrimination, or deprived of these rights in a manner that violated the Constitutional safeguards against self-incrimination.

Court Decision

The Court reversed the decision of the state Supreme Court.

Rationale for the Decision

Chief Justice Warren delivered the decision of the Court. The issue at hand is under what circumstances may a statement be obtained, and what the Constitutional safeguards surrounding the acquisition of the statement are. In a majority of the cases, a statement is obtained while in police custody, which brings into question the availability of the knowledge that a suspect might have of his basic right against self-incrimination. A suspect is essentially "cut off from the outside world," which provides for intimidating circumstances. Without a warning of basic rights, a suspect might be inclined to admit to various acts or actions, purely by succumbing to what he or she believes to be pressure from the acting authority figures. This provides for "psychological intimidation." Whether we like it or not, interrogation will take place in a room that is sealed from the outside world, so the ongoing must be taken at face value, or left in the hands of the prosecution to provide the burden of proof in relation to the fact that none of the rights of the interrogated were violated. As cited in Bram v. United States (168 U.S. 532), "… A confession is voluntary in law if, and only if, it was, in fact, voluntarily made." Therefore, a set of pre-interrogation warnings must be issued to guarantee that a suspect understands his right against self-incrimination, as well as the privileges surrounding that. First, a suspect must be advised of his right to remain silent, as not to indict himself. Second, the suspect must be made aware of the fact that he has a right to counsel, and that if he is too poor to pay for counsel, then the government will make one available to him. The right to counsel applies to the interrogation process, as well as a trial. In no way can the request for counsel be denied. And finally, the suspect has the right to terminate the interrogation at any time. The burden will rest on the government to prove that a confession obtained outside of the presence of an attorney was not coerced in any fashion as to violate the rights of the defendant. These warnings are to be given before any questioning begins, as to protect both the government, as well as the defendant.

Concurring Opinion

The opinion was concurred in part by Justice Clark.

Dissenting Opinion

The dissenting opinion was written by Justice Clark, and joined by Justice Harlan and Justice White. Justice Clark states that the ratio of improper police interrogation practices compared to correct procedure is not balanced in any way, and the rights of suspects are rarely violated. It is stated that the new advisement process will "kill the patient," namely the patient being police agencies across the country, as they now have to make a suspect aware of his rights, provide an attorney, and cover the costs of the attorney if necessary. Furthermore, a failure to follow these rules will result in the deletion of any confession or statement made by a defendant. This will essentially handcuff the police, and not allow them to do their job properly. Also, in accordance with the Solicitor General, the right to counsel does not necessarily mean that a defense attorney must be present during interrogation, and only that an attorney must be made available to the defedant. Citing Haynes v. Washington (373 U.S. 503, 515 (1963)), it is noted, "interrogation has long been recognized as undoubtedly an essential tool in effective law enforcement." By limiting the process, law enforcement officers will have a difficult time properly exercising the functions of their job. However, in concurrence, a lack of given warnings during some portion of the proceedings would not allow for a confession to be validly admitted into evidence in a court of law.

Holding of the Court

The court has decided that a set of warnings must be administered before any custodial interrogation begins. This set of warnings includes the instruction to a suspect that he has the right to remain silent and that anything said outside of silence can be used in court, that the suspect has the right to the presence of an attorney, and if the suspect cannot afford an attorney, one will be appointed, and in conclusion, the suspect has the right to terminate the interrogation at any time.

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