Law School Case Brief
Michigan v. Tucker - 417 U.S. 433, 94 S. Ct. 2357 (1974)
The procedural safeguards, known as the Miranda rules, are not themselves rights protected by the Constitution but are instead measures to insure that the right against compulsory self-incrimination is protected.
Prior to the actual police interrogation of a suspect arrested on a charge of rape, defendant Thomas Wayne Tucker answered questions of the police by stating, insofar as relevant, that he did not want an attorney and that he understood his constitutional rights. The police further advised Tucker that any statements he might make could be used against him at a later date in court, but did not advise him that Tucker, as an indigent, would be furnished counsel free of charge. During the interrogation he named an alibi witness, Henderson, whose later statements discredited Tucker's account as to where he spent the night of the crime. These events all occurred prior to the date of Miranda v Arizona, 384 U.S. 436, 16 L.Ed.2d 694, 86 S.Ct. 1602, 10 A.L.R.3d 974, which required that an indigent in-custody suspect be advised of his right to appointment of counsel. Prior to Tucker's post-Miranda trial in a Michigan state court, the trial court, although excluding Tucker's own statements taken during the interrogation, denied defendant's motion to exclude the testimony of Henderson, who testified at the trial at which Tucker was convicted. His conviction was affirmed by both the Michigan Court of Appeals and by the Michigan Supreme Court. Tucker then filed a petition for habeas corpus in the United States District Court for the Eastern District of Michigan, which granted the requested relief on the ground that Henderson's testimony could not be admitted since the application of such an exclusionary rule was necessary to protect defendant's Fifth Amendment right against compulsory self-incrimination. The United States Court of Appeals for the Sixth Circuit affirmed without opinion. The United States Supreme Court granted the State's petition for certiorari review.
Should a witness’ testimony have been excluded because it violated a defendant's right against compulsory self-incrimination?
Holding that the police's failure to fully give the defendant his Miranda warnings only implicated the prophylactic standards of the warnings, and not the U.S. Const. amend V. privilege against self-incrimination that they were designed to protect, theUnited States Supreme Court reversed the judgment. The Court noted that Tucker had been apprised of his right to counsel, that he had stated that he did not want an attorney, and that the only defect was the failure to inform Tucker that counsel would be provided free if he could not afford one. The Court held that this was a far cry from the compulsory incrimination prohibited by the Fifth Amendment, which Miranda was designed to prevent. The Court held that this failure did not require the exclusion of evidence obtained as a result of the statement, particularly where the statement itself was excluded. The Court noted Tucker's statement was not involuntary, and that the trustworthiness of the witness' evidence was not implicated by the circumstances surrounding the interrogation.
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