Law School Case Brief
Miranda v. Arizona - 384 U.S. 436, 86 S. Ct. 1602 (1966)
In the context of custodial interrogation, once warnings have been given, the subsequent procedure is clear. If the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease. At this point he has shown that he intends to exercise his Fifth Amendment privilege; any statement taken after the person invokes his privilege cannot be other than the product of compulsion, subtle or otherwise. Without the right to cut off questioning, the setting of in-custody interrogation operates on the individual to overcome free choice in producing a statement after the privilege has been once invoked. If the individual states that he wants an attorney, the interrogation must cease until an attorney is present. At that time, the individual must have an opportunity to confer with the attorney and to have him present during any subsequent questioning. If the individual cannot obtain an attorney and he indicates that he wants one before speaking to police, they must respect his decision to remain silent.
Defendants were arrested by the police, who later obtained confessions from them while they were confined in interrogation rooms. The trial court, where each of the defendants was charged, admitted the confessions into evidence, and thereafter convicted each defendant. Defendants sought a review of the trial court's judgment.
Should the confessions obtained from a defendant who was subjected to custodial police interrogation be admitted as evidence at trial?
According to the Court, when an individual was taken into custody and subjected to questioning, the U.S. Const. amend. V privilege against self-incrimination was jeopardized. To protect the privilege, procedural safeguards were required. A defendant was required to be warned before questioning that he had the right to remain silent, and that anything he said can be used against him in a court of law. A defendant was required to be told that he had the right to the presence of an attorney, and if he cannot afford an attorney one was to be appointed for him prior to any questioning if he so desired. After these warnings were given, a defendant could knowingly and intelligently waive these rights and agree to answer questions or make a statement. The Court held that evidence obtained as a result of interrogation was not to be used against a defendant at trial unless the prosecution demonstrated the warnings were given, and knowingly and intelligently waived. Effective waiver required that the accused was offered counsel but intelligently and understandingly rejected the offer. Presuming waiver from a silent record was impermissible.
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