ANALYSIS OF MIRANDA V ARIZONA
One of the most significant cases to be decided upon by the United States Supreme Court during the twentieth century is the case of Miranda v. Arizona. When decided in 1966, it created immediate controversy, and much of that controversy exists in present day criminal law. Miranda v. Arizona is also the basis for one of the most well-known portions of a police officer’s job – that is, reciting Miranda Rights when arresting an individual, so they are apprised of what rights they are afforded. In more than forty years since its decision, Miranda v. Arizona has greatly influenced law and society throughout the United States.
This landmark case originated when Ernesto Miranda was arrested in Arizona on charges of kidnapping and rape. According to an entry in the Columbia Electronic Encyclopedia, Miranda was “identified in a police lineup…questioned…confessed, and…signed a written statement without being told that he had a right to a lawyer”. (Miranda v. Arizona, 2007) His confession was used during his trial and a verdict was handed down finding him guilty of the crimes as charge. Miranda, at the time of his arrest, was a Mexican immigrant living in Arizona, poor in both wealth and education. Unknowledgeable of United States criminal law procedures and police procedures, Miranda was unaware of the Fifth Amendment provision that provides the right against self-incrimination, and so freely gave his confession to the arresting police officers. Also unaware of the Sixth Amendment provision that provides the right to legal counsel, he did not ask for legal counsel to be present during his interrogation, nor was it suggested or provided by the arresting officers. In what his defense would claim was a directed written confession, he wrote out his acknowledgment of the crimes committed as well as an acknowledgment of his right against self-incrimination, although he apparently did not understand that portion of his confession, even as he wrote it. (McBride, 2006)
After his conviction was handed down in criminal court, Miranda was sentenced to 20-to-30 years on each count. His attorney appealed to the Arizona Supreme Court on the grounds that the police officers who arrested Miranda and subsequently took his statement had not informed him of the rights he had under United States law against self-incrimination and for legal counsel. Therefore, his attorney argued that Miranda’s confession should never have been used as evidence at his trial and as a means for conviction. On the opposing side, the state argued that Miranda had been arrested in the past, and so should have past legal knowledge of his rights against self-incrimination and for legal counsel. On appeal to the Arizona Supreme Court, the conviction was upheld. (Background Summary & Beyond Miranda, 2002)
The case reached the United States Supreme Court on writ of certiorari, where it was joined by Vignera v. New York, Westover v. United States, and California v. Stewart, all cases of a similar nature. The Supreme Court, in a five to four decision, found for Miranda. In the majority decision, the following points were held: statements could not be used from persons in police custody unless they were adequately informed of their rights against self-incrimination; statements could not be taken that were not given of free will; the right against self-incrimination is integral to our judicial process; the government carries the burden of proving that the rights afforded by the Fifth and Sixth Amendments have been explained to all suspects; and if during an interrogation, the person in custody chooses to stop speaking and invokes his Fifth or Sixth Amendment rights, questioning must stop at once. (Miranda v. Arizona, 1966) Ironically, when Miranda was retried in Arizona with his confession excluded, he was again convicted.
The most significant impact that Miranda v. Arizona has had on the American people, American society, and the American judicial process is the use of the Miranda Warning by police officers when making an arrest. When arrested, prisoners are warned in the following language, taken directly from the majority decision: “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 appointed for you.” (Background Summary & Beyond Miranda, 2002) In an age where police and crime shows are highly popular on television – CSI and Law & Order to name only the start – most American citizens can recite the Miranda warning by heart. But while most Americans are familiar with this language, most are equally unfamiliar with the case from which it stems as well as the Amendments to United States Constitution that the recitations of these rights protect.
Several significant cases followed behind Miranda v. Arizona, and their decisions were made largely based on the holdings from Miranda. In Harris v. New York, a statement made by Harris was used to impeach his testimony at trial. He had not been Mirandized when he made his statement, and therefore argued that that statement could not be used against him. The Supreme Court, interpreting the rights of Harris as well as further clarifying the decision in Miranda, stated that “Miranda did not mean that evidence barred from use during the prosecution’s case could not be used for any purpose”. (Background Summary & Beyond Miranda, 2002) What that meant was that since the prosecution did not use his statement as a part of its own case but instead used it only to refute his sworn testimony, it was permissible.
In New York v. Quarles, a woman was raped at gunpoint. When the police arrived, she described the person who had assaulted her and pointed them in the direction of a nearby store, where she said he had gone after raping her. The police went to the store, identified a suspect and noticed that he was wearing an empty gun holster. The police then asked Quarles about the location of his gun, and he gave that information freely. He was arrested and Mirandized afterwards. At trial, the attorneys for Quarles argued that his statement about the whereabouts of his gun should be excluded, as he was not advised of his rights until afterwards. The Supreme Court found against Quarles on the grounds that “The police officer acted to further public safety and therefore the statement made by the defendant telling of the location of the weapon before his Miranda rights were read to him was admissible in court”. (Background Summary & Beyond Miranda, 2002)
And interesting interpretation of Miranda arose in Illinois v. Perkins, decided in 1990. In order to gain evidence against a suspect, an informer infiltrated a prison population and obtained information from Perkins that was later used to convict him of murder. Because the statements were not protected by a Miranda warning, and because Perkins did not in fact realize that he was giving a statement to a police informer, his defense claimed that those statements could not be used at trial. The Supreme Court, in a decision deemed controversial because of the differences between Perkins and Miranda, “held that conversations between suspects and undercover officers are not held in a “police-dominated atmosphere” and therefore Miranda warnings are not necessary”. (Background Summary & Beyond Miranda, 2002)
The response to the Miranda decision has not been restricted to subsequent court cases and American Society. Congressional legislation has also been enacted as a response to the holding in Miranda as well as the Supreme Court’s statement in that case “that Congress and the states are free to develop their own safeguards to replace the rules set forth in Miranda, so long as they are as effective as Miranda in protecting a suspect’s right against compelled self-incrimination”. (Hendrie, 1997) And so, in response to the 1966 decision, Congress passed legislation in 1968, 18 U.S.C. 3501, that further clarified the way in which evidence and statements can be legally obtained from suspects. According to Hendrie, a lawyer employed by the FBI, 18 U.S.C. 3501 “provides that a federal court must look at the totality of the circumstances in determining if a statement is voluntary, and that if ‘the trial judge determines that the confession was voluntarily made it shall be admitted in evidence’”. (Hendrie 1997) This legislation, therefore, does not make the assumption presumed in Miranda that suspects in police custody are always in a coercive environment. It instead does assume that suspects may at times make voluntary statements in disregard to the fact that they are permitted the right against self-incrimination as well as the right to counsel.
Through public interpretation, television portrayal, Supreme Court decisions and Congressional legislation, Miranda v. Arizona has remained a hot-button issue in American jurisprudence for more than forty years. In addition to the case’s connection with the Fifth and Sixth Amendment, it is also widely acknowledged as an important case in defining the Due Process Clause of the Fourteenth Amendment. The very significance of this case and its years of controversial influence on all areas of law and order simply shows that in America, one can never be granted too many rights – even those accused of crime. Only when all citizens are afforded equal rights will justice be served.
Background Summary & Beyond Miranda (2002). The Supreme Court Historical Society.
Retrieved March 19, 2007 from http://www.landmarkcases.org/miranda/beyond.html.
Hendrie, E. (1997). Beyond Miranda. FBI Law Enforcement Bulletin. Retrieved March 19,
2007 from http://www.fbi.gov/publications/leb/1997/mar976.htm.
McBride, A. (2006). The Supreme Court Expanding Civil Rights Landmark Cases Miranda v.
Arizona. Retrieved March 19, 2007 from
Miranda v. Arizona, 384 U.S. 436 (1966). Retrieved March 19, 2007 from
Miranda v. Arizona. (2007). Columbia Electronic Encyclopedia (6th Ed.). Retrieved March 19,
2007 from http://www.infoplease.com/ce6/history/A0833372.html.
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