Law School Case Brief
Rhode Island v. Innis - 446 U.S. 291, 100 S. Ct. 1682 (1980)
The Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent. The term "interrogation" under Miranda refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect. The latter portion of this definition focuses primarily upon the perceptions of the suspect, rather than the intent of the police. A practice that the police should know is reasonably likely to evoke an incriminating response from a suspect thus amounts to interrogation. But, because the police surely cannot be held accountable for the unforeseeable results of their words or actions, the definition of interrogation can extend only to words or actions on the part of police officers that they should have known were reasonably likely to elicit an incriminating response.
Shortly after a taxicab driver, who had been robbed by a man wielding a sawed-off shotgun, identified a picture of defendant Innis as that of his assailant, a local patrolman spotted Innis, who was unarmed, on the street, arrested him, and advised him of his rights under Miranda v. Arizona, 384 U.S. 436. Within minutes of the arrest, other police arrived on the scene, including a police sergeant and captain, both of whom again advised Innis of his Miranda rights. After Innis stated that he understood his Miranda rights and wanted to speak with a lawyer, the captain directed that Innis be placed in a police car and driven to the police station accompanied by three patrolmen. While the police car was proceeding to its destination, two of the patrolmen conversed with each other concerning the possibility that one of the handicapped children from the nearby school might find a weapon with shells and get hurt. Innis, overhearing the conversation, told the officers to turn the car around so that he could show them where a shotgun was located. Interrupting the trip to the police station after the car had been on the road for only a few minutes, the police returned to the scene of the arrest where a search for the shotgun was in progress. On arrival, Innis was again advised of his Miranda rights. He replied that he understood his rights, but "wanted to get the gun out of the way because of the kids in the area in the school." Innis then led the police to a nearby field where he pointed out a shotgun. Subsequently, upon being indicted for the kidnapping, robbery, and murder of the deceased taxicab driver, Innis was convicted of such offenses in the Superior Court of Kent, County, Rhode Island, at a trial in which the shotgun and the testimony relating to its discovery had been admitted into evidence. On appeal, the Supreme Court of Rhode Island set aside the conviction, holding, among other things, that Innis had been subjected to subtle coercion that was the equivalent of interrogation after Innis invoked his Miranda right to counsel. The State was granted a writ of certiorari.
Was Innis subjected to subtle coercion that was the equivalent of interrogation after he had invoked his Miranda right to counsel?
According to the Supreme Court of the United States, the Miranda safeguards came into play whenever a person in custody was subjected to either express questioning or its functional equivalent. The Court held that the term "interrogation" under Miranda referred not only to express questioning, but also to any words or actions on the part of the police that the police should know were reasonably likely to elicit an incriminating response from a suspect. In the case at bar, the Court held that Innis was not interrogated within the meaning of Miranda when the police officers voiced safety concerns about children finding the weapon from the crime and Innis interrupted them to say he would show them where the gun was located.
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