Petitioner
State of Oregon
Respondent
Carl Ray Mathiason
Petitioner's Claim
That the Fifth Amendment right to be free from self-incrimination does not require police to give Miranda warnings to a person who is not under arrest andis not deprived of freedom of action.
Chief Lawyer for Petitioner
W. Michael Gillette
Chief Lawyer for Respondent
Gary D. Babcock
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart, Byron R. White (unsigned)
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall, John Paul Stevens
Place
Washington, D.C.
Date of Decision
25 January 1977
Decision
Law enforcement personnel need not read Miranda rights to a person before interviewing and receiving a confession from the person provided the person is not under arrest and is free to leave, even if the person is at a police station.
Significance
The ruling limited the scope of Miranda v. Arizona (1966). In that case, the Court held that a person in police custody must be advised of her rights before the police may ask questions. Instead of holding that "police custody" includes questioning that takes place inside a police station, the Mathiason Court held that a person must be arrested or somehow confined before Miranda warnings are required.
In 1966, the U.S. Supreme Court delivered a landmark decision in Miranda v. Arizona, holding that a criminal suspect who is in police custody mustbe advised of certain constitutional rights before a law enforcement officermay question the person. In the primary prosecution that constituted the Miranda case, police officers had questioned a rape suspect while the suspect was in jail, without advising the suspect of his right to an attorney. The High Court struck down the suspect's confession and reversed his conviction, making new law in the process. Prior to Miranda, courts examined thetotality of the circumstances surrounding a confession to determine whetherit was made voluntarily. Miranda threw out that approach and established that a confession by a person who is in police custody is involuntary andtherefore inadmissible in court if the interrogating officers do not advise the person of his or her basic legal rights as a criminal suspect. These rights, by virtue of the case name, became known as "Miranda" rights, and they include the right to an attorney, the right to remain silent, and the right to be free from self-incrimination.
The Miranda decision was controversial. Deemed by many in the law enforcement community as hostile to law enforcement, the Miranda case wasdecided by a divided Court, and its import has been eroded by subsequent cases. One of those cases was Oregon v. Mathiason.
A Violation of Miranda?
The Mathiason case began when an officer of the Oregon State Police was called to investigate a burglary at a home near Pendleton, Oregon. The victim of the burglary named Carl Mathiason as a possible suspect. Mathiason wasa friend of the victim's son and was on parole from prison. After the officertried in vain to contact Mathiason, he left a card for Mathiason, asking himto call on the telephone. Mathiason called the next day, and the officer asked Mathiason to come to the police station to meet. Approximately 90 minuteslater, Mathiason arrived at the state patrol office, which was housed in a building with several other state agencies. The officer shook hands with Mathiason and led him to an office, where the two sat at a desk. The officer described the burglary and told Mathiason that he was not under arrest, but he alsosaid that he believed that Mathiason had committed the crime and that the police had found his fingerprints at the scene. The latter statement--that Mathiason's fingerprints had been found--was a fabrication, but Mathiason did notknow that. The officer told Mathiason that he would be best served by telling the truth; Mathiason sat for a few minutes and then decided to confess to the crime.
At trial, Mathiason moved the court to exclude evidence of his confession. Mathiason argued that he was entitled to, but did not receive, notice of his Miranda rights, and that he confessed only because he thought it was to his benefit to do so. Mathiason was convicted in a bench trial and his conviction was affirmed by the Oregon Court of Appeals. However, the Supreme Court of Oregon reversed, holding that Mathiason was in custody and was entitled to his Miranda rights. The state of Oregon appealed the decision to the U.S. Supreme Court, which reversed without hearing oral arguments and without giving it full consideration.
The Court Clarifies Miranda
In a per curiam opinion (one that is not credited to any particular justice), the Court recounted the facts and procedural disposition of the caseand conducted a quick analysis. Miranda, according to the Court, was directed toward police procedures in "custodial interrogations." Citing Miranda, the Court explained that custodial interrogation is "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." Inthis case, Mathiason was not in custody or deprived of his freedom of action.Mathiason was free to leave the patrol office, and he in fact did leave thepatrol office after giving his confession. The Court acknowledged that the interview may have been somewhat coercive, but "[a]ny interview of one suspected of a crime by a police officer will have coercive aspects to it" because "the police officer is part of a law enforcement system which may ultimately cause the suspect to be charged with a crime." Nevertheless, "Miranda warningsare required only where there has been such a restriction on a person's freedom as to render him `in custody.'"
Unfaithful to Miranda?
Justices Brennan, Marshall, and Stevens dissented. Justice Brennan disagreedwith the Court's decision to deny oral arguments and limit its review of thecase. Justice Marshall objected to the Court's strict reading of Miranda. Marshall conceded that Mathiason may not have been under arrest, "but surely formalities alone cannot control." If Mathiason "entertained an objectively reasonable belief that he was not free to leave," then he was, under the law, deprived of his freedom of action. Marshall opined that it would have been reasonable for Mathiason to believe that he was not free to leave, considering the isolated, unfamiliar setting of the patrol office.
Marshall called for a more careful reading of Miranda. "[F]aithfulnessto Miranda," wrote Marshall, "requires us to distinguish situations that resemble the `coercive aspects' of custodial interrogation from those that more nearly resemble general on-the-scene questioning . . . which Miranda states usually can take place without warnings." Marshall noted that the Court's decision was based only on the Fifth Amendment to the U.S. Constitution, and he roguishly reminded state courts that they "remain free, in interpreting state constitutions, to guard against the evil clearly identified bythis case."
Justice Stevens complained of the Court's cursory treatment of the case and raised an issue that had been ignored by the majority. Mathiason, Stevens noted, was on parole subject at the time of the questioning. Law enforcement officers have greater power to question parolees than regular citizens, and parolees are, by and large, familiar with police procedures. Considering these factors, the Miranda warning seemed inappropriate. Conversely, Mathiason's parole status may have been a factor requiring Miranda warnings. If a parolee is technically in legal custody, Stevens reasoned, "a parolee should always be warned." The landmark case of Miranda had been qualified, said Stevens,and the Court "would have a better understanding of the extent of that qualification . . . if we had the benefit of full argument and plenary consideration."
Impact
The ruling in Mathiason gave police more freedom to question criminalsuspects and left uninformed persons more susceptible to coercive police interrogations. The decision pared down the significance of Miranda and signaled its demise. Preceded by Michigan v. Tucker (1974) and succeededby several other cases, Mathiason became part of a string of cases that slowly drained Miranda of its precedential value. In 1984, the HighCourt held in New York v. Quarles that Miranda rights are not required if the questioning is prompted by an immediate concern for public safety. Two years later, in Moran v. Burbine (1986) the Court appeared to return to the pre-Miranda law of police questioning by looking only at thetotality of the circumstances. In that case, officers prevented a suspect from seeing his lawyer, but the Court held that under the circumstances the incriminating statements were made voluntarily and did not have to be excluded from trial. However, in Withrow v. Williams (1993), the Court reappliedsome value to the reading of Miranda rights when it held that, generally, a habeas corpus petitioner can base the petition on the failure of policeto issue Miranda warnings before questioning.
Related Cases
The Whitmore Confessions
On 23 April 1964, George Whitmore, Jr., witnessed an assault on Elba Borreroin Brooklyn and volunteered a description of the attacker to the police. Similarities between the Borrero case and the recent murder of Minnie Edmonds inthe same neighborhood prompted detectives to have another talk with Whitmore.After questioning him for 22 hours without the presence of an attorney, detectives announced that Whitmore had confessed to both the Borrero assault andthe Edmonds killing. The detectives also got Whitmore to sign a confession that he had committed the unsolved double murder of Janice Wylie and Emily Hoffert in Manhattan.
Whitmore contended that the confessions had been beaten out of him. Even whenanother arrest was made in the Wylie-Hoffert murders, Whitmore still was notdismissed, causing technicalities in his defense in the Borrero assault case. His guilt was assumed on racist grounds.
On 13 June 1966, when the Supreme Court handed down the Miranda decision regarding the rights of crime suspects, they acknowledged that coercive interrogations could produce false confessions. "[T]he most conspicuous exampleoccurred in New York in 1964," stated a footnote, "when a African American confessed to two brutal murders and a rape which he had not committed. When this was discovered, the prosecutor was reported as saying: `Call it what you want--brain-washing, hypnosis, fright. The only thing I don't believe is thatWhitmore was beaten.'"
Sources
Knappman, Edward W., ed. Great American Trials. Detroit, MI: Visible Ink Press, 1994.
State of Oregon
Respondent
Carl Ray Mathiason
Petitioner's Claim
That the Fifth Amendment right to be free from self-incrimination does not require police to give Miranda warnings to a person who is not under arrest andis not deprived of freedom of action.
Chief Lawyer for Petitioner
W. Michael Gillette
Chief Lawyer for Respondent
Gary D. Babcock
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart, Byron R. White (unsigned)
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall, John Paul Stevens
Place
Washington, D.C.
Date of Decision
25 January 1977
Decision
Law enforcement personnel need not read Miranda rights to a person before interviewing and receiving a confession from the person provided the person is not under arrest and is free to leave, even if the person is at a police station.
Significance
The ruling limited the scope of Miranda v. Arizona (1966). In that case, the Court held that a person in police custody must be advised of her rights before the police may ask questions. Instead of holding that "police custody" includes questioning that takes place inside a police station, the Mathiason Court held that a person must be arrested or somehow confined before Miranda warnings are required.
In 1966, the U.S. Supreme Court delivered a landmark decision in Miranda v. Arizona, holding that a criminal suspect who is in police custody mustbe advised of certain constitutional rights before a law enforcement officermay question the person. In the primary prosecution that constituted the Miranda case, police officers had questioned a rape suspect while the suspect was in jail, without advising the suspect of his right to an attorney. The High Court struck down the suspect's confession and reversed his conviction, making new law in the process. Prior to Miranda, courts examined thetotality of the circumstances surrounding a confession to determine whetherit was made voluntarily. Miranda threw out that approach and established that a confession by a person who is in police custody is involuntary andtherefore inadmissible in court if the interrogating officers do not advise the person of his or her basic legal rights as a criminal suspect. These rights, by virtue of the case name, became known as "Miranda" rights, and they include the right to an attorney, the right to remain silent, and the right to be free from self-incrimination.
The Miranda decision was controversial. Deemed by many in the law enforcement community as hostile to law enforcement, the Miranda case wasdecided by a divided Court, and its import has been eroded by subsequent cases. One of those cases was Oregon v. Mathiason.
A Violation of Miranda?
The Mathiason case began when an officer of the Oregon State Police was called to investigate a burglary at a home near Pendleton, Oregon. The victim of the burglary named Carl Mathiason as a possible suspect. Mathiason wasa friend of the victim's son and was on parole from prison. After the officertried in vain to contact Mathiason, he left a card for Mathiason, asking himto call on the telephone. Mathiason called the next day, and the officer asked Mathiason to come to the police station to meet. Approximately 90 minuteslater, Mathiason arrived at the state patrol office, which was housed in a building with several other state agencies. The officer shook hands with Mathiason and led him to an office, where the two sat at a desk. The officer described the burglary and told Mathiason that he was not under arrest, but he alsosaid that he believed that Mathiason had committed the crime and that the police had found his fingerprints at the scene. The latter statement--that Mathiason's fingerprints had been found--was a fabrication, but Mathiason did notknow that. The officer told Mathiason that he would be best served by telling the truth; Mathiason sat for a few minutes and then decided to confess to the crime.
At trial, Mathiason moved the court to exclude evidence of his confession. Mathiason argued that he was entitled to, but did not receive, notice of his Miranda rights, and that he confessed only because he thought it was to his benefit to do so. Mathiason was convicted in a bench trial and his conviction was affirmed by the Oregon Court of Appeals. However, the Supreme Court of Oregon reversed, holding that Mathiason was in custody and was entitled to his Miranda rights. The state of Oregon appealed the decision to the U.S. Supreme Court, which reversed without hearing oral arguments and without giving it full consideration.
The Court Clarifies Miranda
In a per curiam opinion (one that is not credited to any particular justice), the Court recounted the facts and procedural disposition of the caseand conducted a quick analysis. Miranda, according to the Court, was directed toward police procedures in "custodial interrogations." Citing Miranda, the Court explained that custodial interrogation is "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." Inthis case, Mathiason was not in custody or deprived of his freedom of action.Mathiason was free to leave the patrol office, and he in fact did leave thepatrol office after giving his confession. The Court acknowledged that the interview may have been somewhat coercive, but "[a]ny interview of one suspected of a crime by a police officer will have coercive aspects to it" because "the police officer is part of a law enforcement system which may ultimately cause the suspect to be charged with a crime." Nevertheless, "Miranda warningsare required only where there has been such a restriction on a person's freedom as to render him `in custody.'"
Unfaithful to Miranda?
Justices Brennan, Marshall, and Stevens dissented. Justice Brennan disagreedwith the Court's decision to deny oral arguments and limit its review of thecase. Justice Marshall objected to the Court's strict reading of Miranda. Marshall conceded that Mathiason may not have been under arrest, "but surely formalities alone cannot control." If Mathiason "entertained an objectively reasonable belief that he was not free to leave," then he was, under the law, deprived of his freedom of action. Marshall opined that it would have been reasonable for Mathiason to believe that he was not free to leave, considering the isolated, unfamiliar setting of the patrol office.
Marshall called for a more careful reading of Miranda. "[F]aithfulnessto Miranda," wrote Marshall, "requires us to distinguish situations that resemble the `coercive aspects' of custodial interrogation from those that more nearly resemble general on-the-scene questioning . . . which Miranda states usually can take place without warnings." Marshall noted that the Court's decision was based only on the Fifth Amendment to the U.S. Constitution, and he roguishly reminded state courts that they "remain free, in interpreting state constitutions, to guard against the evil clearly identified bythis case."
Justice Stevens complained of the Court's cursory treatment of the case and raised an issue that had been ignored by the majority. Mathiason, Stevens noted, was on parole subject at the time of the questioning. Law enforcement officers have greater power to question parolees than regular citizens, and parolees are, by and large, familiar with police procedures. Considering these factors, the Miranda warning seemed inappropriate. Conversely, Mathiason's parole status may have been a factor requiring Miranda warnings. If a parolee is technically in legal custody, Stevens reasoned, "a parolee should always be warned." The landmark case of Miranda had been qualified, said Stevens,and the Court "would have a better understanding of the extent of that qualification . . . if we had the benefit of full argument and plenary consideration."
Impact
The ruling in Mathiason gave police more freedom to question criminalsuspects and left uninformed persons more susceptible to coercive police interrogations. The decision pared down the significance of Miranda and signaled its demise. Preceded by Michigan v. Tucker (1974) and succeededby several other cases, Mathiason became part of a string of cases that slowly drained Miranda of its precedential value. In 1984, the HighCourt held in New York v. Quarles that Miranda rights are not required if the questioning is prompted by an immediate concern for public safety. Two years later, in Moran v. Burbine (1986) the Court appeared to return to the pre-Miranda law of police questioning by looking only at thetotality of the circumstances. In that case, officers prevented a suspect from seeing his lawyer, but the Court held that under the circumstances the incriminating statements were made voluntarily and did not have to be excluded from trial. However, in Withrow v. Williams (1993), the Court reappliedsome value to the reading of Miranda rights when it held that, generally, a habeas corpus petitioner can base the petition on the failure of policeto issue Miranda warnings before questioning.
Related Cases
- Miranda v. Arizona, 348 U.S. 436 (1966).
- Michigan v. Tucker, 417 U.S. 433 (1974).
- New York v. Quarles, 467 U.S. 649 (1984).
- Moran v. Burbine, 475 U.S. 412 (1986).
- Withrow v. Williams, 507 U.S. 680 (1993).
The Whitmore Confessions
On 23 April 1964, George Whitmore, Jr., witnessed an assault on Elba Borreroin Brooklyn and volunteered a description of the attacker to the police. Similarities between the Borrero case and the recent murder of Minnie Edmonds inthe same neighborhood prompted detectives to have another talk with Whitmore.After questioning him for 22 hours without the presence of an attorney, detectives announced that Whitmore had confessed to both the Borrero assault andthe Edmonds killing. The detectives also got Whitmore to sign a confession that he had committed the unsolved double murder of Janice Wylie and Emily Hoffert in Manhattan.
Whitmore contended that the confessions had been beaten out of him. Even whenanother arrest was made in the Wylie-Hoffert murders, Whitmore still was notdismissed, causing technicalities in his defense in the Borrero assault case. His guilt was assumed on racist grounds.
On 13 June 1966, when the Supreme Court handed down the Miranda decision regarding the rights of crime suspects, they acknowledged that coercive interrogations could produce false confessions. "[T]he most conspicuous exampleoccurred in New York in 1964," stated a footnote, "when a African American confessed to two brutal murders and a rape which he had not committed. When this was discovered, the prosecutor was reported as saying: `Call it what you want--brain-washing, hypnosis, fright. The only thing I don't believe is thatWhitmore was beaten.'"
Sources
Knappman, Edward W., ed. Great American Trials. Detroit, MI: Visible Ink Press, 1994.
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