Miranda v. Arizona is the Supreme Court case where it was held that the custodial interrogation of an individual must be accompanied by an instruction that the person has the right to remain silent, any statements made can be used against the person, and that the individual has the right to counsel, either retained or appointed. Absent these safeguards, statements made in this context will be inadmissible in court. These rights have since become known as the Miranda rights.
Important Note:
After the recent Supreme Court opinion in 2022, Vega v. Tekoh, violating Miranda rights does not provide a basis for a § 1983 claim. Meaning, officers who fail to Mirandize individuals prior to an interrogation have qualified immunity.
Background:
In the majority opinion delivered by Chief Justice Warren, the Court addressed procedures that originally, must have been observed to avoid violating the Fifth Amendment when questioning an individual subject to police interrogation. This decision, found in a consolidated case where several unrelated individuals were questioned for prolonged periods of time without being informed of their Miranda rights, reaffirmed the Constitutional principles that “No person . . . shall be compelled in any criminal case to be a witness against himself” and that “the accused shall . . . have the Assistance of Counsel.” These rights, according to the Court, were enshrined within the Constitution to protect against the overzealous enforcement of police authority.
The Court summarized its holding as thus: “the prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination.” In this way, the Court held that not only is the individual made aware of their rights, but of the consequences of foregoing them. Furthermore, these rights exist throughout the questioning process. Even where an individual voluntarily, knowingly waives these rights, they may still exercise them later in the process, if they wish. If such a waiver occurs, the burden of proof rests on the government to demonstrate it was made within the bounds of the law.
The Court appeared to be particularly concerned with what went on in police-dominated atmospheres during interrogation procedures where individuals were cut off from the outside world. Absent advising these persons of their rights, police might coerce or force confessions from potential suspects through psychological or physical means. After a lengthy explication of the right against self-incrimination, the Court applied a liberal construction to this right and found that its privilege must be applied throughout the questioning process. The Court concluded by noting that it does not intend its outlined procedures to unnecessarily constrict the pursuit of effective law enforcement, but rather that absent changes in law by the states or federal government, these procedures must be followed. A statement obtained without violating the above procedures is admissible in court (absent any other evidentiary objections).
In a dissenting opinion, Justice Harlan, joined by Justices Stewart and White, noted the Court’s history of treating admissibility cases like the one before it had occurred on a case-by-case basis. Justice Harlan also recognized the Court’s history of giving recognition to the public interest in the value of suspect questioning. In sum, the protections already afforded to defendants within statutes and case law, means that additional protections required by the majority overstep Fifth Amendment jurisprudence. This dissent also weighed policy concerns. For example, truthful confessions by competent individuals made under brief and non-coercive questioning are now inadmissible in court if the police officer fails to warn the individual of their Miranda rights. Moreover, Justice Harlan argued that the protections granted by the majority will not be upheld by the officer who was likely to violate the pre-Miranda rights of the accused from the start.
Justice White, in another dissent joined by Justices Harlan and Stewart, asserted that the history and language of the Fifth Amendment meant that its protections only applied in criminal proceedings, not custodial interrogations.
Justice Clark, dissenting in part and concurring in part, criticized the majority for going too far and the dissent for doing too little. Justice Clark was concerned with the lack of information and empirical knowledge on whether the protections instituted by the majority would be functional. Rather, the Court should continue to abide by the “totality of circumstances” rule formulated in Haynes v. Washington.
Regardless of the dissents, the majority’s opinion and adoption of Miranda rights has since become entrenched within criminal law.
[Last updated in August of 2022 by the Wex Definitions Team]