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Law School Case Brief

Oregon v. Hass - 420 U.S. 714, 95 S. Ct. 1215 (1975)

Rule:

It does not follow from Miranda that evidence inadmissible against an accused in the prosecution's case in chief is barred for all purposes, provided of course that the trustworthiness of the evidence satisfies legal standards. The impeachment process undoubtedly provides valuable aid to the jury in assessing petitioner's credibility. The benefits of this process should not be lost. Assuming that the exclusionary rule has a deterrent effect on proscribed police conduct, sufficient deterrence flows when the evidence in question is made unavailable to the prosecution in its case in chief and 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 the use of his earlier conflicting statements.

Facts:

After having been arrested by an Oregon police officer on suspicion of burglary, defendant William Hass was given his Miranda rights. On the way to the police station, Hass expressed the wish to telephone his attorney. The officer replied that he could do so as soon as they arrived at the police station. While still in the police vehicle, Hass stated to police that he took two bicycles and that he returned one and hid the other. Hass pointed out to police the location of the hidden bicycle. At trial in Oregon state court, Hass testified to his innocence, but the police officer repeated the inculpatory information furnished to him by Hass. At the request of the defense, the trial court advised the jury that this information may not be used by them as proof of Hass' guilt, but may be considered only as it bore on his credibility. The jury returned a verdict of guilty. On appeal, the Oregon Court of Appeals, feeling itself bound by earlier decisions from the Supreme Court of Oregon, reversed on the ground that the inculpatory statements made by Hass were improperly used to impeach his testimony. The Supreme Court of Oregon affirmed. The State was granted a writ of certiorari.

Issue:

Were the police officer's testimony admissible for impeachment purposes?

Answer:

Yes.

Conclusion:

The Supreme Court Oregon's judgment was reversed. The Supreme Court of the United States held that Hass' statements made after asking for legal representation could properly have been used for impeachment purposes. Evidence which was inadmissible against the accused in the prosecution's case in chief was not barred for all purposes, so long as the trustworthiness of the evidence satisfied legal standards. The shield provided by Miranda should not have been perverted into a license to use perjury by way of a defense, free from the risk of confrontation with prior inconsistent utterances. Hass' credibility was properly impeached by the use of his earlier conflicting statements.

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