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Law School Case Brief

Rhode Island v. Innis - 446 U.S. 291, 100 S. Ct. 1682 (1980)

Rule:

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.

Facts:

Shortly after a taxicab driver, who had been robbed by a man wielding a sawed-off shotgun, identified a picture of Innis as that of his assailant, a Providence, R. I., 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. When other police officers arrived at the arrest scene, Innis was twice again advised of his Miranda rights, and he stated that he understood his rights and wanted to speak with a lawyer. Innis was then placed in a police car to be driven to the central station in the company of three officers, who were instructed not to question Innis or intimidate him in any way. While en route to the station, two of the officers engaged in a conversation between themselves concerning the missing shotgun. One of the officers stated that there were "a lot of handicapped children running around in this area" because a school for such children was located nearby, and "God forbid one of them might find a weapon with shells and they might hurt themselves." Innis interrupted the conversation, stating that the officers should turn the car around so he could show them where the gun was located. Upon returning to the scene of the arrest where a search for the shotgun was in progress, Innis was again advised of his Miranda rights, replied that he understood those rights but that he "wanted to get the gun out of the way because of the kids in the area in the school," and then led the police to the shotgun. Before trial on charges of kidnaping, robbery, and murder of another taxicab driver, the trial court denied Innis’ motion to suppress the shotgun and the statements he had made to the police regarding its discovery, ruling that Innis had waived his Miranda rights, and Innis was subsequently convicted. The Rhode Island Supreme Court set aside the conviction and held that Innis was entitled to a new trial, concluding that Innis had invoked his Miranda right to counsel and that, contrary to Miranda's mandate that, in the absence of counsel, all custodial interrogation then cease, the police officers in the vehicle had "interrogated" respondent without a valid waiver of his right to counsel.

Issue:

Was Innis 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?

Answer:

No

Conclusion:

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. 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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