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Miranda v. Arizona

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Miranda v. Arizona
LitigantsErnesto Miranda v. Arizona
ArguedFebruary 28–29, 1966
DecidedJune 13, 1966
Citation384 U.S. 436
HoldingsCustodial interrogation requires warnings and waiver to be admissible
MajorityEarl Warren
JoinmajorityHugo Black, William O. Douglas, William J. Brennan Jr., Abe Fortas
ConcurringPotter Stewart
DissentJohn Marshall Harlan II, Byron White, Tom C. Clark

Miranda v. Arizona

Miranda v. Arizona was a landmark United States Supreme Court case that established the requirement for custodial interrogation warnings now known as "Miranda rights." The decision transformed criminal procedure by mandating safeguards for suspects during police interrogations, reshaping practices of the Federal Bureau of Investigation, state Arizona Attorney General, and municipal police departments across the United States. The ruling influenced subsequent litigation at the Supreme Court of the United States, legislative responses by state legislatures, and scholarly debate in Harvard Law School, Yale Law School, and other institutions.

Background

Ernesto Miranda, a resident of Phoenix, Arizona, was arrested by the Phoenix Police Department in 1963 after detectives connected him to a kidnapping and rape investigated by the Maricopa County Sheriff's Office and prosecutors in the Maricopa County Attorney's Office. The case occurred amid broader attention to criminal procedure rights generated by decisions such as Gideon v. Wainwright and Escobedo v. Illinois. Miranda's confession, obtained during interrogation at the Phoenix Police Department, was central to the prosecution by the Arizona Attorney General's Office. The trial in the Superior Court of Arizona featured testimony from officers from the Phoenix Police Department and argument from the defense counsel, raising questions about the voluntariness of statements under precedents like Brown v. Mississippi and Chavez v. Martinez.

Case details

Miranda was tried and convicted in the Superior Court of Arizona before appeal to the Arizona Supreme Court and then to the Supreme Court of the United States. The prosecution relied on a recorded confession elicited by detectives from the Phoenix Police Department without advising Miranda of rights recognized in prior decisions by the Supreme Court of the United States such as Escobedo v. Illinois and Brown v. Mississippi. Miranda's defense invoked counsel from the American Civil Liberties Union and arguments referencing the Fifth Amendment to the United States Constitution and the Sixth Amendment to the United States Constitution. The issue presented was whether the Fifth Amendment privilege against self-incrimination and the Sixth Amendment right to counsel required law enforcement to provide warnings before custodial interrogation—affecting prosecutors in jurisdictions including Cook County, Los Angeles County, and New York County.

Supreme Court decision

In a 5–4 opinion authored by Chief Justice Earl Warren, the Supreme Court of the United States held that the prosecution could not use statements stemming from custodial interrogation of a defendant unless it demonstrated the use of procedural safeguards to secure the privilege against self-incrimination. The majority established that suspects must be informed of the right to remain silent, that anything said may be used in court, the right to consult with an attorney and to have an attorney appointed, and the right to end questioning—principles codified in later practice by police in cities such as Chicago, Houston, and Philadelphia. Concurring and dissenting opinions were filed by Justices including Potter Stewart, John Marshall Harlan II, Byron White, and Tom C. Clark, reflecting debates rooted in earlier rulings like Weeks v. United States and Wolf v. Colorado.

The decision articulated procedural safeguards designed to protect the Fifth and Sixth Amendment rights of individuals in custody, linking to doctrines from cases such as Malloy v. Hogan and Massiah v. United States. The Miranda warnings influenced statutes and procedures in state legislatures like the California State Legislature and the New York State Legislature, and trained personnel in organizations including the Federal Bureau of Investigation, the Central Intelligence Agency, and municipal law enforcement academies. Criminal defense practice at institutions such as Columbia Law School and NYU School of Law adapted; prosecutors in offices like the Manhattan District Attorney's Office and the Los Angeles County District Attorney's Office revised charging and interrogation strategies. The ruling affected appellate practice in the United States Court of Appeals for the Ninth Circuit and prompted operational changes in police departments from San Francisco Police Department to the Miami-Dade Police Department.

Miranda also prompted statutory and administrative responses, including legislative efforts in the United States Congress and model rules considered by the American Bar Association. The decision shaped media coverage in outlets like the New York Times and the Washington Post and influenced public policy debates at think tanks such as the Brookings Institution and the Cato Institute.

Subsequent developments and criticism

Following Miranda, the Supreme Court of the United States refined and limited aspects of the decision in cases such as Dickerson v. United States, which reaffirmed Miranda, and Berghuis v. Thompkins, which addressed invocation and waiver. The exclusionary rule and exceptions like the public safety exception from New York v. Quarles modified application in practice. Critics from scholars at Stanford Law School and commentators associated with the Heritage Foundation and American Enterprise Institute argued Miranda impeded effective policing, while defenders at Georgetown University Law Center and the ACLU emphasized constitutional protections. Legislative attempts to alter Miranda by the United States Congress and state assemblies generated debates resolved in part by subsequent Supreme Court jurisprudence in Harris v. New York and Missouri v. Seibert.

Academic commentary in journals such as the Yale Law Journal, the Harvard Law Review, and the Columbia Law Review has examined Miranda's empirical effects on confession rates and criminal convictions, citing studies from institutions including University of Chicago Law School and University of Michigan Law School. International discussions connected Miranda to safeguards in the European Convention on Human Rights and practices in countries like Canada and Australia. Miranda remains a central doctrine in criminal procedure education at law schools including University of California, Berkeley School of Law and ongoing litigation in federal and state courts.

Category:United States Supreme Court cases