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Law School Case Brief

Harris v. New York - 401 U.S. 222, 91 S. Ct. 643 (1971)

Rule:

The shield provided by Miranda cannot be perverted into a license to use perjury by way of a defense, free from the risk of confrontation with prior inconsistent utterances. A defendant's credibility can be appropriately impeached by use of his earlier conflicting statements.

Facts:

During cross-examination at his trial, Harris was questioned regarding specified statements Harris made to the police immediately following his arrest. The statements partially contradicted Harris’ direct testimony, and the state sought to impeach Harris with his statements. However, the State made no effort to use the statements in its case in chief, conceding that the statements were inadmissible under Miranda. Harris was subsequently convicted of selling heroin to an undercover police officer, and the appellate court affirmed Harris’ conviction. 

Issue:

Did Miranda prevent the state from using Harris’ statement to the police to confront Harris with prior inconsistent utterances to impeach his credibility?

Answer:

No

Conclusion:

The court held that Miranda did not prevent the state from using Harris’ statement to the police to confront defendant with prior inconsistent utterances. Thus, the court concluded that Harris’ credibility was appropriately impeached by use of his earlier conflicting statements.

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