Thank You For Submiting Feedback!
The United States Supreme Court has never indicated that the "rigidity" of Miranda extends to the precise formulation of the warnings given a criminal defendant.
An individual, Randall James Prysock, apprehended for the commission of murder was brought to a police substation and advised of his rights under Miranda v Arizona (1966) 384 US 436, 16 L Ed 2d 694, 88 S Ct 1602, 10 ALR3d 974. Prysock declined to talk and, since he was a minor, his parents were notified. With his parents present he decided to answer police questions, at which time the Miranda warnings were given again, the police informing him, among other things, that he had "the right to talk to a lawyer before he was questioned, have him present with you while you are being questioned, and all during questioning" and "the right to have a lawyer appointed to represent you at no cost to yourself." At trial, the Superior Court of Tulare County, California, denied the defendant's motion to suppress the statement that he subsequently made at interrogation, and he was convicted by a jury of first-degree murder and of other offenses. On appeal, the Court of Appeal of California, Fifth Appellate District, reversed the convictions and ordered a new trial, ruling that Prysock’s incriminating statements had to be excluded from consideration by the jury because Prysock was not properly advised of his right to the services of a free attorney before and during interrogation, that the warnings given to Prysock were inadequate because he was not explicitly informed of his right to have an attorney appointed before further questioning, and that the requirements of Miranda were not met in the case. The Supreme Court of California denied a petition for hearing.
Did the warnings given to Prysock prior to a recorded conversation with a police officer satisfy the requirements of Miranda v. Arizona, 384 U.S. 436 (1966)?
The appellate court held that Prysock was not properly advised of his right to counsel during the interrogation. The Court held that the rigidity of Miranda did not extend to the precise formulation of the warnings given. The Court found that Prysock was informed of his right to have a lawyer present prior to and during interrogation and that he could have one appointed if could not afford one. The Court held that the appellate court erred because it was clear that Prysock’s Miranda rights were fully conveyed.