Case Brief 5
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CRIM 404
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Computer Science
Date
May 3, 2024
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Uploaded by ProfessorIronRam33
Riley Herbert
CRIM 404
Professor Oakman
11 Apr 2024
Case Brief 5: Miranda v. Arizona, (1966) 384 U.S. 436
Miranda v. Arizona
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Jurisdiction/Date: SCOTUS, Jun 1966
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Plaintiff: Ernesto Miranda
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Defendant: State of Arizona
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Trial Court Verdict or Judgment: Miranda was found guilty at trial, a decision that was upheld on
appeal by the Supreme Court of Arizona.
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Who is appealing?: Miranda
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Decision in this appeal: The Court decided with Miranda, and overturned the decision of the
lower court.
Contextual placement
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Miranda v. Arizona is a landmark case that thoroughly altered American criminal law. By
requiring law enforcement to inform citizens of their constitutional rights (to remain silent if they
do not wish their statements to be used against them in a court of law, and to have an attorney
advising them and one appointed for them if they cannot afford it) prior to interrogation,
SCOTUS greatly extended the scope of illegal compulsions to confess. Today, the "Miranda
Warnings" are a routine procedure in law enforcement, and are prevalent in modern culture.
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It is worth noting another landmark case, Berghuis v. Thompkins, 560 U.S. 370 (2010), which
rules more recently that the mere silence of a suspect denotes that they are aware of their rights,
and any voluntary statements made are effectively waivers of those rights. Many legal scholars
see this as a true erosion of procedures set in place by
Miranda
. Additionally, the United States
Court of Appeals for the Fourth Circuit found that "the admissibility of confessions in federal
court is governed by 18 U.S.C.A. § 3501 (West 1985), rather than Miranda" in Dickerson v.
United States, 530 U.S. 428 (2000). "The Senate Report accompanying § 3501 specifically stated
that "the intent of the bill is to reverse the holding of Miranda v. Arizona, 384 U.S. 436, 16 L. Ed.
2d 694, 86 S. Ct. 1602 (1966)." Other various state-level courts have further undermine
Miranda,
exploring "The prophylactic rather than Constitutional nature of the Miranda Warnings."
Important facts of this case
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Plaintiff's position/argument(s): Miranda's case revolved around the fact that he had not been
informed of his right to an attorney prior to signing his written confession or of his right to remain
silent before giving an oral confession, which was used against him at trial despite his defense
attorney's objections. Although the Supreme Court of Arizona agreed with the trial court's
decision to include the confession due to the fact that Miranda had never requested an attorney,
his position still held that the grueling hours of his interrogation and his ignorance of his
constitutional rights nullified the voluntary nature of his confession, and it should have been
excluded at trial.
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Defendant's position/argument(s): The State of Arizona argued that law enforcement had not
violated Miranda's Fifth Amendment rights by obtaining his confession without an attorney
present. Miranda had not requested one, and thus the State held that his constitutional rights had
not been violated, and SCOTUS ought to affirm the rulings of the lower courts, allowing the
confession to remain valid.
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Statement of the issue (5 U.S. (1 Cranch) 154 (1803)
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By not informing Ernesto Miranda of his right to remain silent or right to an attorney, or
of the fact that his statements would be used against him in a court of law, did law
enforcement violate his Fifth Amendment rights?
Holding
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Yes.
Rationale of the court:
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In the majority opinion, along with Justices Black, Douglas, Brenann, and Fortas, Chief Justice
Warren holds that "we will not presume that a defendant has been effectively apprised of his
rights and that his privilege against selfincrimination has been adequately safeguarded on a record
that does not show that any warnings have been given or that any effective alternative has been
employed" (Miranda v. Arizona, 108 (1966) 384 U.S. 436). They also note that a waiver of those
rights cannot be a silent admission. Furthermore, the court reasons that "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" (Miranda v. Arizona, 16 (1966) 384 U.S. 436). This rationale relies on
the self-incrimination clause of the Fifth Amendment and the Sixth Amendment right to an
attorney. Thus, the court ruled the means by which the written confession was obtained
unconstitutional, and ordered a retrial for Miranda without use of the confession.
Personal Response
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I think the fact that Miranda was still convicted and sentenced without the confession
demonsrates that this decision was not soft on crime, but rather, as the majority opinion hold, a
manifestation of long-held ideas about criminal justice. I belive the rationale of the court,
especially the insistence that unreasonable long interrogations and faliure to inform suspects of
their rights is a constitutional violation, makes perfect sense.
Dissents and Concurrences
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In a Dissent in Part and Concurrence in Part, Justice Clark finds that the majority opinion takes a
few libertieis too many, while the other two dissenting opinions do not go far enough in their
analysis. He relies on Haynes v. Washington, 373 U.S. 503, 515 (1963) to espouse a ""a totality of
circumstances" approach. Justice Clark would " consider in each case whether the police officer
prior to custodial interrogation added the warning that the suspect might have counsel present at
the interrogation and, further, that a court would appoint one at his request if he was too poor to
employ counsel."
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Justice Harlan, together with Justices Stewart and White, find in a Dissent that the court is going
beyond the scope of Constiutional analysis with its descion. The Dissen ends with a quote from a
fromer Justice Jackson: "This Court is forever adding new stories to the temples ofconstitutional
law, and the temples have a way of collapsing when one story too many is added" (Miranda v.
Arizona, 156 (1966) 384 U.S. 436).
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Justice White also Dissents with Harlan and Stewart, and finds that the "factual and textual bases"
of the majority opinion are lacking. He finds the ruling to be too strong an alteration of current
criminal procedure.
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