Miranda v. Arizona

I

Introduction

Miranda v. Arizona, landmark court case of 1966 in which the Supreme Court of the United States ruled that police officers must advise suspects of certain legal rights before arrest and questioning. In Miranda the Court described a four-part warning that police officers must give to a suspect who is arrested or otherwise detained. The warning is designed to inform suspects of their rights not to incriminate themselves and to have the assistance of counsel.

Under the Miranda decision, if the police failed to provide the necessary warning, the prosecution could not use any statements by the suspect as evidence in a criminal proceeding. Any evidence that police found as a result of such statements was also inadmissible. However, later decisions by the Court have modified this rule and eroded the protections that the Miranda decision afforded criminal defendants.

II

Historical Background

The belief that government should not force a person to give self-incriminating information developed in England during the 17th century. At that time people began to oppose the Star Chamber, a British court established in 1487 and authorized to torture defendants to compel confessions. The Star Chamber also administered an oath requiring individuals to answer any questions asked of them, including those that might demonstrate guilt. After Parliament abolished the Star Chamber in 1641, English common law included a privilege (right) against self-incrimination. This protection was adopted by the American colonies and included in the Bill of Rights (the first ten amendments to the Constitution of the United States). The Fifth Amendment provides that a person may not “be compelled in any criminal case to be a witness against himself.”

Despite this constitutional guarantee, studies conducted in the early 1930s showed that police extensively used force, threats, or false promises to obtain information from suspects. Physical force, though it had become less common, was still being used to coerce confessions at the time of the Miranda case. More widespread, as some police training manuals of the 1960s showed, was the use of psychological coercion. In Miranda the Supreme Court discussed these manuals, which stressed the importance of holding suspects incommunicado—cut off from family and friends—so that they would be unaware of their rights and intimidated by the power of the law. These police manuals outlined techniques such as nonstop questioning to tire out suspects and falsely informing suspects that there were witnesses or evidence against them.

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III

Legal Background

The Miranda decision followed other decisions of the 1960s designed to prevent violations of the constitutional rights of suspects and criminal defendants. In Gideon v. Wainwright (1963) the Supreme Court held that the Sixth Amendment, which guarantees criminal defendants the assistance of counsel, requires state governments to provide attorneys for indigent (poor) criminal defendants. The following year, in Escobedo v. Illinois, the Court held that a suspect has a right to have an attorney present when being interrogated in police custody as well as during a trial. In Miranda v. Arizona the Court addressed the question of how to enforce a suspect’s right to counsel and right against self-incrimination. The Court concluded that police officers must specifically inform suspects of these rights and inform them that if they give up these rights their statements can be used against them.

IV

Circumstances of the Miranda Decision

The Miranda decision resulted from four cases that raised similar issues and were decided together by the Supreme Court. The circumstances of the case that gives its name to the decision involved Ernesto Miranda, a 23-year-old truck driver who was arrested in 1963 on charges of kidnapping and rape. After two hours of questioning by officers at a police station, Miranda confessed to the crime. Miranda did not request an attorney, and there was no allegation of police misconduct during questioning. Miranda was convicted and sentenced to a term of 20 to 30 years in prison. On appeal of his conviction, Miranda’s attorneys asserted that the interrogation process was intimidating by its very nature. Therefore, they argued, Miranda’s statements had been compelled and should not have been admitted as evidence against him at trial.

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