Miranda v. Arizona (1966)
Miranda v. Arizona (1966) was one of the Warren Court’s most controversial decisions in the field of criminal justice. The case centered on Ernesto Miranda, who was suspected of rape and kidnapping and was arrested by the Phoenix police. Initially Miranda maintained his innocence, but after two hours of intense police questioning, he signed a written confession. Miranda’s confession was used in court and he was found guilty of the crimes. His conviction was challenged on appeal as a violation of the Fifth and Fourteenth Amendment right against self-incrimination.
In a 5–4 decision, the Supreme Court agreed with Miranda and held that the confession was obtained in violation of the Constitution. The Court found that the interrogation process exerted a heavy toll on the suspect emotionally and that without access to legal representation, suspects may be weakened to the point of confession. Chief Justice Earl Warren wrote that in order to protect a suspect’s right against self-incrimination, the police must follow minimal procedural requirements before questioning. These procedural requirements became known as the Miranda rights and advise suspects of the rights that they have while in police custody. Suspects must be informed that they have the right to remain silent, that anything that they say can and will be used against them in a court of law, and that they have the right to an attorney and if they cannot afford one, a lawyer will be provided for them. Failure to issue the Miranda rights invalidates any confession and makes the statement inadmissible in a court of law. A suspect may waive his or her Miranda rights, but the burden is on the government to prove that the rights were actually waived.
This decision, along with its earlier decision in Mapp v. Ohio (1961), led to the charge that the Warren Court was “soft on crime.” The main fear of critics was that these decisions were tying the hands of law enforcement with additional procedural requirements that made it more difficult for them to do their job. Subsequent Supreme Court cases have narrowed the scope of Miranda without overruling it completely. The requirements for Miranda warnings were loosened in New York v. Quarles (1984), in which the justices decided that Miranda rights are not required in emergency situations, such as when the life of the arresting officer is in jeopardy. Suspects also do not have to be informed of the specific charge that they are being held for as part of the Miranda rights, according to the 1987 decision in Colorado v. Spring. The Miranda rights, however, have survived direct assault in cases such as Dickerson v. United States (2000), in which an increasingly conservative Supreme Court affirmed the main holding of the case and stated that the warnings were constitutional rules rather than procedural guidelines.
| BIBLIOGRAPHY:
Richard Leo and George C. Thomas, eds., The Miranda Debate: Law, Justice and Policing (Boston: Northeastern University Press, 1998). |
Heather Elise Trela
Last Updated: 2006
SEE ALSO: Fourteenth Amendment; Incorporation (Nationalization) of the Bill of Rights; New Judicial Federalism