Miranda v. Arizona Summary | quimbee.com
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Miranda v. Arizona Summary | quimbee.com

– [Narrator] In the 1960s,
Miranda versus Arizona was a huge victory for individual rights. The case established a
set of arrest procedures, including the famous
right to remain silent that Americans now take for granted. Miranda was a consolidation of four cases. Ernesto Miranda confessed
after questioning by Arizona Police while he was in custody
at a police station. Before confessing, Miranda wasn’t advised of his right to counsel. At trial, his confession was admitted and a jury convicted him
of kidnapping and rape. The Supreme Court of Arizona
affirmed Miranda’s conviction. Like Miranda, defendants Michael
Vignera and Carl Westover confessed to crimes after
extensive custodial interrogations without being notified of their rights. Their convictions were affirmed. However, the Supreme Court of California reversed Roy Allen Stewart’s conviction because the record was silent on whether he had been
advised of his rights. The United States Supreme
Court accepted these four cases to determine what kinds of custodial interrogation
procedures were required to adequately safeguard
the Fifth Amendment right against self-incrimination. The court held that without
certain hallmark warnings regarding the right to remain silent and the right to counsel, statements made during
custodial interrogation were inadmissible at trial. Writing for a five-justice majority, Chief Justice Warren concluded that prosecutors couldn’t use statements from custodial interrogations without procedural safeguards. Custodial interrogation occurs when law enforcement
officers question a person who has been arrested
and taken into custody, or otherwise deprived of freedom of action in any significant way. Warren described custodial interrogation as inherently coercive. Cutting suspects off from
contact with the outside world creates an environment
ripe for intimidation. Acting within a closed,
hostile environment, police officers can prey
upon individual weaknesses at the expense of individual liberties. The risk of psychological
intimidation was plain in several of the consolidated cases here. For example, Miranda
suffered from mental illness, and Stewart had dropped out
of school in the sixth grade. Due to these concerns, the Constitution requires a
number of procedural safeguards that relieve some of the pressure put upon people in
custodial interrogation. Prior to any questioning while in custody, a person must be informed of
the right to remain silent and that anything said can
be used as evidence of guilt. The arrestee must also be notified of the right to an attorney, and that if the arrestee
can’t pay for an attorney one will be provided for free. Any waiver of these
rights must be voluntary. If a person refuses to be
questioned at any point, law enforcement can’t
continue the questioning. The fact that a person
answers some questions doesn’t mean the person waives the right to consult with an attorney or to stop the interrogation
at a later point. After establishing these principles, the court held that the
statements of all four men were inadmissible. The court reversed the
convictions of Miranda, Vignera, and Westover, and then affirmed the
California Supreme Court’s reversal of Stewart’s conviction. Justice Clark dissented
from the court’s judgment as to the reverse convictions, and concurred in the judgment on Stewart. Lacking empirical evidence on the impact of the court’s
procedure safeguards, Clark worried the
majority had gone too far. Clark would’ve employed a
totality-of-the-circumstances test to evaluate whether each
statement was voluntary. Justice Harlan, joined by Justices Stewart and White, dissented. The majority’s procedures discouraged any kind of confession. Even if the Fifth Amendment applied to pre-trial
custodial interrogations, it hardly supported the
majority’s strict procedures. Legislative reform could
craft a better solution and would be supported by empirical data on the effect of any new procedures on law enforcement practice. Justice White also wrote his own dissent. In White’s view, no Fifth
Amendment jurisprudence supported the majority’s procedures. While it frequently fell to
the court to make new law, there was no logical basis for assuming that custodial interrogations were inherently coercive, or that the majority’s procedures would render the statements voluntary. Moreover, the majority’s procedures could weaken criminal law enforcement. Just two years later, Richard Nixon advocated reversing Miranda in his 1968 presidential campaign. He supported Congress’s passing of the Omnibus Crime Control
and Safe Streets Act of 1968, which purported to abolish
Miranda in the federal system. In Dickerson versus United States, the court eventually struck down the law and ruled that Miranda warnings were still constitutionally
required in federal cases.


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