MIRANDA v. ARIZONA (No. 759) 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966)
I. Facts.
Miranda (“D”, the defendant) was arrested in Phoenix, Arizona, on suspicion of kidnapping and rape. After two hours of police interrogation, he signed a written confession. However, during the questioning, he was never informed that he had the right to remain silent, anything he said could be used against him in court, and he had the right to an attorney, either hired or appointed. His confession was used as evidence at trial, and he was convicted.
II. Issue.
l Whether statements obtained from a defendant during custodial interrogation is admissible in court if conducted without informing the defendant’s basic constitutional rights such as right to silence and right to counsel under the Fifth Amendment and Sixth Amendment.
III. Reasoning.
A. Rules.
1. Fifth Amendment
- Nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law.
Sixth Amendment
- In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defense.
Escobedo v. State of Illinois, 378 U.S. 478, 84 S.Ct. 1758, 12 L.Ed.2d 977 (1964)
- Refusing the right to remain silence and to have assistance in counsel is unconstitutional.
B. Application
1. As enunciated in Fifth Amendment and Sixth Amendment, an individual suspect is entitled to the right not to make self-incriminating statements and to have the assistance of counsel for their defense. If such rights are violated, it would be unconstitutional. Escobedo v. State of Illinois, 378 U.S. 478, 84 S.Ct. 1758, 12 L.Ed.2d 977 (1964). However, when a suspect is taken into police custody, the nature of custodial interrogation is inherently coercive. A lay person may not be aware of their constitutional rights and is highly likely to make self-incriminating statements because of the intimating and coercive atmosphere. In this case, even without any physical threat from the police officers, D was denied the right to counsel and was indirectly compelled to make a self-incriminating written confession during custodial interrogation at the police station. D was then convicted based on that confession.
Since evidence unlawfully obtained is likely to be tainted and a conviction based on such tainted evidence would undermine justice, procedural safeguards are required to protect the constitutional rights of individual suspects and to ensure a fair trial. Here, the court established so-called ‘Miranda rule’ to protect these rights. Under this rule, police officers must inform an individual in custody that they have the right to remain silent, that any statement made may be used as evidence against them, and that they have the right to the presence of an attorney. An individual may waive effectuation of these rights but the waiver must be made voluntarily, knowingly and intelligently. Since D in this case was not provided such procedural safeguards when taken into custody, the admissibility of the evidence obtained during the custody is invalid.
IV. Holding.
The judgment reversed. Unless procedural safeguards are used to secure the privilege against self-incrimination, the statements made during custodial interrogation are inadmissible.