Miranda v. Arizona
**Overview of Miranda v. Arizona**
Miranda v. Arizona is a landmark Supreme Court case from 1966 that established crucial protections for individuals in police custody during interrogation. The case centered on Ernesto Miranda, who was not informed of his rights against self-incrimination or his right to counsel before being interrogated by police, leading to a confession that was later deemed inadmissible. The ruling mandated that law enforcement must inform suspects of their rights, commonly known as "Miranda rights," before questioning. These rights include the right to remain silent, the right to have an attorney present, and the provision of an attorney if the suspect cannot afford one.
This decision was significant in reinforcing the protection of accused individuals, although it sparked debates regarding the balance between law enforcement procedures and individual rights. Subsequent rulings have refined the application of Miranda rights, raising questions about their clarity and effectiveness, particularly for vulnerable populations such as juveniles. Critics argue that misunderstandings about these rights can lead to coercion, while supporters maintain that Miranda safeguards essential civil liberties. The case has had lasting implications on police practices and the legal landscape related to self-incrimination, shaping ongoing discussions about justice and individual rights in the United States.
Miranda v. Arizona
Date: June 13, 1966
Citation: 384 U.S. 436
Issues:Immunity against self-incrimination; right to counsel
Significance: The Supreme Court overturned the conviction of a man who had not been informed of his right to remain silent and to have counsel appointed for him. It also created guidelines for the police in advising suspects of their rights.
Chief Justice Earl Warren delivered the 5-4 majority decision holding that Ernesto Miranda had his constitutional rights denied him when he was interrogated by police at the station while under arrest. The officers failed to warn him that he had a right to remain silent, to know what he said could be used against him, to have an attorney, and to have an attorney appointed for him if he could not afford one. Miranda made statements harmful to himself, then confessed to the crime and was convicted. Before the Miranda ruling, his confession would not have been regarded as coerced and therefore inadmissible.
Two years earlier in Malloy v. Hogan (1964), the Court mandated that states provide guarantees against self-incrimination in their criminal court proceedings and extended through dicta the need for the protection of the accused in police custody. In Miranda, Warren spelled out in some detail the requirements for protecting suspects over the objections of the four dissenting justices. Although he did not mandate the exact words of the Miranda warning, Warren did say what needed to be done to eliminate what the Court perceived as police abuse of the earlier “voluntary” confession rule. He stated that suspects must be given the following four warnings, although not necessarily in these exact words: You have the right to remain silent; anything you say can and will be used against you; you have the right to talk to a lawyer before being questioned and to have him or her present when being questioned; and if you cannot afford a lawyer, the court will provide one for you before questioning begins if you so desire.
Miranda was the most advanced step the Court took in defending those accused of crimes, and it provoked an outpouring of criticism that the Court was soft on crime. At the same time, scholars and others charge that the opinion did not go far enough in defending the rights of the accused.
Later court decisions have restricted when and where the Miranda rights apply. Oregon v. Mathiason (1977) clarified that police do not have to warn a suspect who is not under arrest, as that person remains at liberty and thus is not in an inherently coercive environment. Similarly, under the Howes v. Fields (2011) ruling, Miranda warnings are unnecessary when the person being interrogated is already in jail for a separate crime. In New York v. Quarles (1984), the court deemed that in a situation of immediate threat to public safety, the greater interest lies in protecting the public than in warning a suspect of his or her rights. This ruling has subsequently been used in terrorism investigations.
Despite these clarifications to Miranda, there is still confusion regarding a suspect's rights during interrogation. For instance, a suspect may invoke or waive the right to remain silent, making it unclear whether silence is a natural right that may be surrendered or whether the person must act in order to gain the right. In Berghuis v. Thompkins (2010) and Salinas v. Texas (2013), the court ruled that the suspect must actively invoke the right to remain silent, as opposed to merely not speaking. This, the justices argue, allows the government to challenge the assertion that the testimony is self-incriminating or to exclude testimony from court evidence.
There is also concern among defendants' rights activists that suspects in general—and juveniles in particular—cannot correctly comprehend and apply the Miranda warnings. Research indicates many reasons for this, including low levels of education; juveniles' inability to foresee long-term consequences of their actions; misunderstanding what evidence can be used in court. They may also distrust of defense lawyers (and, in the case of juveniles, parental or custodial adults), whom they mistakenly believe must collaborate against them, or they may fear or have uncertainty about who will pay for appointed counsel. Further, most suspects do not understand or are unaware that the right to silence can be invoked at any point, not just the outset, of interrogations.
Thus, although Miranda has been important in preserving individuals' rights while allowing law enforcement officers to gather much-needed intelligence, the warnings remain controversial and, at least to some, unclear.
Bibliography
Drogin, Eric Y., and Richard Rogers. "Juveniles and Miranda." GPSolo 32.4 (2015): 70–71. Academic Search Complete. Web. 7 Jan. 2016.
Erastus-Obilo, Bethel. Everything You Need to Know about Miranda Rights and Warning. Newmarket: BrainMass, 2012. Digital file.
Holland, Brooks. "Miranda v. Arizona: 50 Years of Judges Regulating Police Interrogation." Insights on Law & Society 16.1 (2015): 4–11. Academic Search Complete. Web. 7 Jan. 2016.
"Miranda v. Arizona." LII. Cornell U Law School, n.d. Web. 7 Jan. 2016.
"Salinas v. Texas." Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. Web. 7 Jan. 2016.