Miranda v. Arizona

Summary

On 13 March 1963 Phoenix police arrested Ernesto Miranda at his home in connection with a kidnapping and sexual assault. After the victim identified him, two officers questioned him in Interrogation Room No. 2 for about two hours. They did not tell him that he could remain silent or have a lawyer present. He emerged with a signed written confession, which included a typed statement that it was made voluntarily and with full knowledge of his legal rights. The confession was used at trial, he was convicted, and the Arizona Supreme Court affirmed. The Court heard his case together with three others raising the same issue: Vignera v. New York, Westover v. United States and California v. Stewart. The question was whether statements obtained by police questioning a suspect in custody may be used against him when he has not been informed of his rights. Miranda's lawyers, John J. Flynn and John P. Frank, argued that the privilege against self-incrimination applies in the police station as well as the courtroom, and that the pressures of incommunicado questioning make warnings and access to counsel necessary. Arizona, through Gary K. Nelson, answered that the longstanding test of voluntariness under the Due Process Clause already forbade coerced confessions, that police questioning is indispensable to solving crimes, and that new rules for interrogation should come from legislatures rather than the Court. By a vote of 5 to 4 the Court reversed Miranda's conviction. Chief Justice Earl Warren traced the right against self-incrimination to the trial of John Lilburne before the Star Chamber in 1637, reviewed police manuals describing techniques of isolation and persuasion, and concluded that custodial interrogation contains inherently compelling pressures. Before questioning, he held, a suspect must be warned that he has the right to remain silent, that anything he says can be used against him in court, that he has the right to the presence of an attorney, and that one will be appointed if he cannot afford one. If he asks for a lawyer or wishes to stay silent, questioning must stop. Warren added that Congress and the states remain free to devise other safeguards equally effective. Justice John Marshall Harlan II, joined by Justices Stewart and White, called the decision a new constitutional code of rules for confessions, unsupported by history or precedent and likely to discourage confessions altogether. Justice Byron R. White, joined by Harlan and Stewart, argued that the Fifth Amendment forbids only compelled testimony and that the Court had no factual basis for presuming every answer in custody compelled. Justice Clark also dissented in a separate opinion. The library text gives substantial excerpts of Warren's opinion and both principal dissents, without Clark's dissent or the footnotes. Miranda was retried in 1967 and convicted on other evidence. Congress passed a statute in 1968 meant to restore the voluntariness test in federal courts, but Dickerson v. United States (2000) held that Miranda announced a constitutional rule that Congress could not override.

Top Lessons

• No man bound to accuse himself

  Warren roots the right against self-incrimination in the old maxim that no one should be compelled to accuse himself, and in the story of John Lilburne before the Star Chamber. The accusatory system, he wrote, requires the government to find its evidence by its own labors rather than drawing it from the mouth of the accused.

• Pressure without force

  The Court found that even without violence, isolation and skilled persuasion in a police station could overbear a suspect's will. White answered that the Fifth Amendment forbids compulsion, not all pressure, and that the Court had not examined any real interrogation.

• A bright line or a case-by-case test?

  Before Miranda, judges asked whether each confession was voluntary under all the circumstances. Warren replaced that inquiry with fixed warnings; Harlan defended the older test as flexible and fair, and called the new rules a constitutional code imposed over widespread objection.

• Weighing the cost to law enforcement

  Arizona and the dissenters warned that the rules would reduce confessions and make crimes harder to solve. Warren replied that the FBI already warned suspects without crippling its work and that the Constitution itself had struck the balance. Both sides took the public's safety seriously.

Verified Quotes

Medical Lens

The opinions concern police questioning and constitutional rights; the brief references to a defendant's mental condition are part of the facts and are not a medical discussion.