Miranda V. Arizona

Miranda v. Arizona384 U.S. 436 (1966)

Vote: 5 (Black, Brennan, Douglas, Fortas, Warren) 4 (Clark, Harlan, Stewart, White)

Summary of the Relevant Law

Miranda V Arizona portrays an in-depth analysis of the custodial interrogations. Through the case, the revelation of the Supreme Court’s decision based on addressing four different cases was evident. In all the instances, the suspects were interrogated by the police, district attorney and detectives in unfamiliar interrogation rooms (Swindler 205). In some of the cases, there was a reduced effort by the officers to dictate the suspect’s rights, which are in contradiction to the interrogation process.

Miranda v. Arizona case denoted the arrest of Miranda and being held custody in a police station. Through the identification by the complaining witness, the police proceeded with the interrogation process. Miranda was not provided with an attorney and the outcomes were the signing of a written confession. During the trial, verbal and dictated confessions were availed to the jury (Hutchinson 923). Miranda received a sentence of 30 years in prison for both rape and kidnapping offenses. Arizona’s Supreme Court judges emphasized that no violation of constitutional rights was shown during the interrogation process.

The court made an emphasis on examining an additional three cases that provided insight into the underlying issue of interrogation procedures. Vignera v. New York, Westover v. the United States, and California v. Stewart were the additional cases essential to understanding custodial procedures. In all the cases, incidents of suspects being apprehended and interrogated without a clear procedural analysis of the various necessary steps towards handling suspects were evident (Swindler 205). As an example, in Vignera v. New York, it was revealed that Vignera had been picked up in connection to a robbery incident. Taken to the police station, Vignera was interrogated for three hours and oral confession and transcripts were made and presented to the jury. However, in the interrogation process, the district attorney was available without the attorney representing Vignera.

Summary of the Complaint

Miranda was adamant at stating that he was not provided with comprehensive representation throughout the interrogation process. At no point throughout the interrogation was Miranda provided information about the right to have an attorney present. Indigent criminal defendants ought to receive a lawyer to defend Miranda against the potential charges. Further, throughout the court process, Miranda’s attorney did not provide adequate defense. Proving that Miranda was insane or mentally defective was not evident from the defense (Hutchinson 923). Miranda emphasized the need for attorneys who would represent his underlying issues throughout the interrogation process. The notion of self-incrimination was a dimension of concern throughout the case. Protection of personal freedom throughout the case was a factor shaping the complaint by the defendant.

Actions taken by the Lower Court

Arizona Trial Court rendered Miranda guilty of the two offences rape. Upon seeking further legal redress at the State Supreme Court, the affirmation of the court was evident. The State court held that Miranda was not adamant at requesting for an attorney and the interrogation process did not reveal any form of coercion. Miranda consequently joined other defendant and embarked on petitioning the Supreme Court of US for appeal. Therefore, the Supreme Court was adamant throughout the court process in dictating the custodial issues that shape the interrogation.

Issues

The main issue surrounding the case was based on the evaluation of the legality of the statement obtained from the individuals’ subject to police interrogation. Throughout the custodial interrogation process, it is vital to examine whether or not the statement can be admissible against the defendant in the criminal trial. Procedures that play a pivotal role in assuring whether the individual’s rights play a central role in both the arrest and interrogation process are dictated in the 5th Amendment ought to be followed. Self-incrimination should not prevail in the interrogation process and clear procedures should be dictated to the suspect (Smith 55). Right from self-incrimination is dictated in the Amendment and was at the center of the debate. Within the interrogation, it is evident that the individual was not accorded information about the essential constitutional rights. The focus on an open avenue for the revelation of personal rights is at the center of the case.

Decisions or Holding

The court judges were emphatic at stating the need for upholding the 5th Amendment both in the court room and in execution of police responsibilities. Through the amendment, it should be the foundation towards serving to protect individuals in all the settings. Specifically, when the freedom of action is hindered in any manner that translates to self-incrimination, the amendment plays a critical role (Hutchinson 922). The prosecution cannot use the statements from an individual who has been compelled during a custodial interrogation, whether exculpatory or inculpatory. However, in the instance that law enforcement demonstrates the implementation of procedural safeguards that assure security against self-incrimination, the statements can be used. The court emphasized that custodial interrogation denotes the questioning process of an individual once in custody or when personal right to movement has been deprived (Smith 55). The judges asserted that the absence of effective guidelines, the process of interrogations of persons who are suspect comprises of the use of coercive approaches that may demean a person. The defendant ought to be warned before questioning of the right to be mum. Law enforcement officer should communicate about the defendant’s right to have an attorney present and in the instance he or she cannot meet the necessary costs, the State will provide before any questioning commences. Through the analysis of the underlying issues, the Supreme Court was quick to reverse the decision made in the Supreme Court of Arizona in Miranda. Additional cases reviewed included the Vignera vs. New York Court of Appeal case and the Court of Appeal for the 9th Circuit in Westover. The in-depth analysis of the compelling reasons defining the case was critical towards the decision made.

Reasoning or Rationale

The right prohibiting self-incrimination is applicable to trials and when a person is in custody. Miranda was not aware of the legal rights. Therefore, the suspect was forced by the police to confess which is in contradiction to the 5th Amendment. Once an individual is in custody, the 5th Amendment dictates that the suspects should be informed of their constitutional rights (Hutchinson 923). The defining factors are inclusive of the right to be silent and have an attorney, if one cannot afford one; the State provides one for him or her.

Supreme Court judges took into in-depth consideration of the usual police tactics and instruction manuals that take the center stage in determining the interrogation procedures. The police may adopt coercive means in obtaining confessions. As an example, a person may be isolated and kept in an unfamiliar setting that may be intimidated. The court was adamant at emphasizing that the police adopted the use of trickery through making fictitious deals for the individual to confess. Despite the techniques used not comprising coercion, the interrogation had the potential to heighten the vulnerability of the defendant.

Separate opinions

Dissent (Judge Harlan)

The holding had the potential to frustrate police officers. Throughout the definition of volunteering to profess ones guilt should be determined in a court. The defendant may have accepted his guilt without coercion and the availability of a warrant should be a defining factor in determining the legality of the interrogation.

Dissent (Judge White)

The dictated conclusion that one’s confession cannot be allowed where the questioning process of the police are coercive, contradicts the notion of common sense in dealing with crime (Hutchinson 922). Non-existent evidence was provided to support the claims of coercion. Ineffectiveness in providing support to the ruling that coercion was evident is ill-informed.

Analysis

The landmark ruling set the standards for police operations. Heightening the need for police to be extensively aware of the constitutional rights of a person in executing their roles is a major outcome of the ruling. Through the case, “Miranda Warnings” emerged as a foundation to apprehending a person (Swindler 205). The warnings are a guideline for police in ensuring the suspect’s rights are protected once in custody. Throughout the execution of roles, it is critical for the police to conform to the underlying rights of a person and dictate clearly of the options for one to be silent and request for an attorney, and if one cannot afford, the State is obliged to provide one.

Works Cited

Hutchinson, Dennis J. “Hail to the Chief: Earl Warren and the Supreme Court.”(1983): 922-930.

Smith, Christopher E. “The Impact of New Justices: The US Supreme Court and Criminal Justice Policy.”Akron L. Rev. 30 (1996): 55.

Swindler, William F. “The Warren Court: Completion of a Constitutional Revolution.”Vand. L. Rev. 23 (1969): 205.