Petitioner
Ernesto Miranda
Respondent
State of Arizona
Petitioner's Claim
That a failure to inform the petitioner of his constitutional right to an attorney made his confession inadmissible in court.
Chief Lawyer for Petitioner
John Flynn
Chief Lawyer for Respondent
Gary K. Nelson, Assistant Attorney General of Arizona
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, Abe Fortas, Earl Warren (writing for the Court)
Justices Dissenting
Tom C. Clark, John Marshall Harlan II, Potter Stewart, Byron R. White
Place
Washington, D.C.
Date of Decision
13 June 1966
Decision
The Court extended a defendant's constitutional right to counsel to include pretrial questioning and required police to advise defendants of their rights.
Significance
Few events have altered the course of American jurisprudence more than the 1963 rape conviction of Ernesto Miranda. The primary evidence against him was aconfession he made while in police custody. How that confession was obtainedexercised the conscience of a nation and prompted the landmark U.S. SupremeCourt decision.
In the early hours of 3 March 1963, an 18-year-old Phoenix, Arizona, movie theater attendant was accosted by a stranger while on her way home from work. He dragged her into his car, drove out to the desert, and raped her. Afterwards he dropped the girl off near her home. The story she told police, often vague and contradictory, described her attacker as a bespectacled Mexican, latetwenties, who was driving an early 1950s car, either a Ford or a Chevrolet.
By chance, one week later, the girl and her brother-in-law saw what she believed was the car, a 1953 Packard, license plate DFL-312. Records showed that this plate was actually registered to a late model Oldsmobile, but DFL-317 wasa Packard, registered to a Twila N. Hoffman; and her boyfriend, Ernesto Miranda, 23, fit the attacker's description almost exactly.
Miranda had a long history of emotional instability and criminal behavior, including a one-year jail term for attempted rape. At police headquarters, he was placed in a lineup with three other Mexicans of similar height and build,though none wore glasses. The victim did not positively identify Miranda butsaid he bore the closest resemblance to her attacker. Detectives Carroll Cooley and Wilfred Young then took Miranda into an interrogation room. He was told, inaccurately, that he had been identified, and asked him if he wanted to make a statement. Two hours later Miranda signed a written confession. There had been no blatant coercion or brutality, and included in the confession wasa section stating that he understood his rights. When the detectives left interrogation room 2, they were pleased, not realizing the legal repercussions that would result from their efforts.
Tainted Evidence
As an indigent, Miranda was granted a court-appointed defender, Alvin Moore.Moore studied the evidence. The state had an apparently unassailable case, buttressed by Miranda's confession. And yet there was something about that confession that Moore found troubling. Convinced that it had been obtained improperly, he intended to move for its inadmissibility.
Only four witnesses appeared for the prosecution: the victim, her sister, andDetectives Cooley and Young. After their testimony, Deputy County Attorney Laurence Turoff told the jury that the victim "did not enter into this act ofintercourse with him [Miranda] willfully, but in fact she was forced to, by his own force and violence, directed against her."
Moore responded by highlighting inconsistencies in the victim's story. She claimed to have been a virgin prior to the attack, an assertion discounted by medical examiners, and could not remember the exact chronology of the night'sevents. Neither did she exhibit any bruising or abrasions after the attack; reason enough for Moore to thunder the jury, "You have in this case a sorrowful case, but you do not have the facts to require that you send a man to prison for rape of a woman who should have resisted and resisted and resisted, until her resistance was at least overcome by the force and violence of the defendant" (an essential requirement under Arizona law at the time; anything lesswas regarded as compliance).
But it was not until cross-examination of Carroll Cooley that Moore struck:
This admission prompted Moore to object to the confession as evidence, but hewas overruled by Judge Yale McFate, who favored the jury with a well-balanced and eminently fair account of the law as it stood at the time. In 1963, theconstitutional right to silence was not thought to extend to the jailhouse.
Consequently, on 27 June 1963, Ernesto Miranda was convicted and sentenced totwo concurrent terms of 20 to 30 years imprisonment.
But Alvin Moore's arguments about the confession had touched off a legal firestorm. Miranda's conviction was appealed all the way to the U.S. Supreme Court. On 13 June 1966, Chief Justice Earl Warren, speaking for a 5-4 majority, for the first time established unequivocal guidelines about what is and what is not permissible in the interrogation room:
Conviction Overturned
With Miranda's conviction overturned, Arizona glumly faced the prospect of having to free its most celebrated prison inmate. Without the confession, the chances of winning a retrial were negligible. Ironically, it was Miranda himself who brought about his own downfall. Expecting to be released after retrial, he had begun a custody battle with his common-law wife, Twila Hoffman, overtheir daughter. Hoffman, angry and fearful, approached the authorities and revealed to them the content of a conversation she had with Miranda after hisarrest, in which he had admitted the rape.
The fresh evidence was all Arizona needed.
Miranda's second trial began 15 February 1967. Much of the case was argued inthe judge's chambers. At issue was whether a common-law wife could testify against her husband. Yes, said County Attorney Robert Corbin. Defense counselJohn Flynn, who had pleaded Miranda's case before the Supreme Court, bitterlydisagreed. After considerable legal wrangling, Judge Lawrence K. Wren ruledsuch evidence admissible, and Twila Hoffman was allowed to tell her story tothe jury. It proved decisive. Miranda was again found guilty and sentenced to20 to 30 years in jail.
On 31 January 1976, four years after being paroled, Ernesto Miranda was stabbed to death in a Phoenix bar fight. The killer fled but his accomplice was caught. Before taking him to police headquarters, the arresting officers read the suspect his rights. In police vernacular, he had been "Mirandized."
Impact
The importance of this case cannot be overstated. Denounced by presidents from Richard Nixon to Ronald Reagan, the Miranda decision has withstood all attempts to overturn it. Framed originally to protect the indigent and theignorant, the practice of "reading the defendant his rights" has become standard operating procedure in every police department in the country. The practice is seen so frequently in television police dramas that today the so-called "Miranda Warnings" are as familiar to most Americans as the Pledge of Allegiance.
Related Cases
Miranda Rights
In Miranda v. Arizona the Court established unequivocal protections that the accused was entitled to during interrogation "while in custody at thestation or otherwise deprived of his freedom of action in any significant way."
Miranda established that the accused must be informed that he or she has the right to remain silent and that if the suspect chooses not to remain silent that anything said can be used against the suspect in court. Before being interrogated the suspect must also be informed of the right to consult with an attorney, and to have legal counsel present during interrogation.
Additionally, the Miranda rule also requires that if the suspect is indigentthat he or she be informed that the court will provide counsel. If the suspect decides to remain silent, then the interrogation must end. Any statements obtained in violation of the suspects' Miranda rights are inadmissible as evidence in court. If the suspect decides to speak without consulting with an attorney then the prosecutor must prove that the suspect willingly waived Miranda rights.
Sources
Biskupic, Joan, and Elder Witt. Congressional Quarterly's Guide to the U.S. Supreme Court. Washington, DC: Congressional Quarterly, Inc., 1997.
Ernesto Miranda
Respondent
State of Arizona
Petitioner's Claim
That a failure to inform the petitioner of his constitutional right to an attorney made his confession inadmissible in court.
Chief Lawyer for Petitioner
John Flynn
Chief Lawyer for Respondent
Gary K. Nelson, Assistant Attorney General of Arizona
Justices for the Court
Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, Abe Fortas, Earl Warren (writing for the Court)
Justices Dissenting
Tom C. Clark, John Marshall Harlan II, Potter Stewart, Byron R. White
Place
Washington, D.C.
Date of Decision
13 June 1966
Decision
The Court extended a defendant's constitutional right to counsel to include pretrial questioning and required police to advise defendants of their rights.
Significance
Few events have altered the course of American jurisprudence more than the 1963 rape conviction of Ernesto Miranda. The primary evidence against him was aconfession he made while in police custody. How that confession was obtainedexercised the conscience of a nation and prompted the landmark U.S. SupremeCourt decision.
In the early hours of 3 March 1963, an 18-year-old Phoenix, Arizona, movie theater attendant was accosted by a stranger while on her way home from work. He dragged her into his car, drove out to the desert, and raped her. Afterwards he dropped the girl off near her home. The story she told police, often vague and contradictory, described her attacker as a bespectacled Mexican, latetwenties, who was driving an early 1950s car, either a Ford or a Chevrolet.
By chance, one week later, the girl and her brother-in-law saw what she believed was the car, a 1953 Packard, license plate DFL-312. Records showed that this plate was actually registered to a late model Oldsmobile, but DFL-317 wasa Packard, registered to a Twila N. Hoffman; and her boyfriend, Ernesto Miranda, 23, fit the attacker's description almost exactly.
Miranda had a long history of emotional instability and criminal behavior, including a one-year jail term for attempted rape. At police headquarters, he was placed in a lineup with three other Mexicans of similar height and build,though none wore glasses. The victim did not positively identify Miranda butsaid he bore the closest resemblance to her attacker. Detectives Carroll Cooley and Wilfred Young then took Miranda into an interrogation room. He was told, inaccurately, that he had been identified, and asked him if he wanted to make a statement. Two hours later Miranda signed a written confession. There had been no blatant coercion or brutality, and included in the confession wasa section stating that he understood his rights. When the detectives left interrogation room 2, they were pleased, not realizing the legal repercussions that would result from their efforts.
Tainted Evidence
As an indigent, Miranda was granted a court-appointed defender, Alvin Moore.Moore studied the evidence. The state had an apparently unassailable case, buttressed by Miranda's confession. And yet there was something about that confession that Moore found troubling. Convinced that it had been obtained improperly, he intended to move for its inadmissibility.
Only four witnesses appeared for the prosecution: the victim, her sister, andDetectives Cooley and Young. After their testimony, Deputy County Attorney Laurence Turoff told the jury that the victim "did not enter into this act ofintercourse with him [Miranda] willfully, but in fact she was forced to, by his own force and violence, directed against her."
Moore responded by highlighting inconsistencies in the victim's story. She claimed to have been a virgin prior to the attack, an assertion discounted by medical examiners, and could not remember the exact chronology of the night'sevents. Neither did she exhibit any bruising or abrasions after the attack; reason enough for Moore to thunder the jury, "You have in this case a sorrowful case, but you do not have the facts to require that you send a man to prison for rape of a woman who should have resisted and resisted and resisted, until her resistance was at least overcome by the force and violence of the defendant" (an essential requirement under Arizona law at the time; anything lesswas regarded as compliance).
But it was not until cross-examination of Carroll Cooley that Moore struck:
Question: Officer Cooley, in the taking of this statement, what didyou say to the defendant to get him to make this statement?
Answer: I asked the defendant if he would . . . write the same story that he just told me, and he said that he would.
Question: Did you warn him of his rights?
Answer: Yes, sir, at the heading of the statement is a paragraphtyped out, and I read this paragraph to him out loud.
Question: I don't see in the statement that it says where he is entitled to the advice of an attorney before he made it.
Answer: No, sir.
Question: Is it not your practice to advise people you arrest that they are entitled to the services of an attorney before they make a statement?
No, sir.
This admission prompted Moore to object to the confession as evidence, but hewas overruled by Judge Yale McFate, who favored the jury with a well-balanced and eminently fair account of the law as it stood at the time. In 1963, theconstitutional right to silence was not thought to extend to the jailhouse.
Consequently, on 27 June 1963, Ernesto Miranda was convicted and sentenced totwo concurrent terms of 20 to 30 years imprisonment.
But Alvin Moore's arguments about the confession had touched off a legal firestorm. Miranda's conviction was appealed all the way to the U.S. Supreme Court. On 13 June 1966, Chief Justice Earl Warren, speaking for a 5-4 majority, for the first time established unequivocal guidelines about what is and what is not permissible in the interrogation room:
Prior to any questioning, the person must be warned that he has a right to remain silent, that anystatement he does make may be used as evidence against him, and that he hasthe right to the presence of an attorney, either retained or appointed . . .
Conviction Overturned
With Miranda's conviction overturned, Arizona glumly faced the prospect of having to free its most celebrated prison inmate. Without the confession, the chances of winning a retrial were negligible. Ironically, it was Miranda himself who brought about his own downfall. Expecting to be released after retrial, he had begun a custody battle with his common-law wife, Twila Hoffman, overtheir daughter. Hoffman, angry and fearful, approached the authorities and revealed to them the content of a conversation she had with Miranda after hisarrest, in which he had admitted the rape.
The fresh evidence was all Arizona needed.
Miranda's second trial began 15 February 1967. Much of the case was argued inthe judge's chambers. At issue was whether a common-law wife could testify against her husband. Yes, said County Attorney Robert Corbin. Defense counselJohn Flynn, who had pleaded Miranda's case before the Supreme Court, bitterlydisagreed. After considerable legal wrangling, Judge Lawrence K. Wren ruledsuch evidence admissible, and Twila Hoffman was allowed to tell her story tothe jury. It proved decisive. Miranda was again found guilty and sentenced to20 to 30 years in jail.
On 31 January 1976, four years after being paroled, Ernesto Miranda was stabbed to death in a Phoenix bar fight. The killer fled but his accomplice was caught. Before taking him to police headquarters, the arresting officers read the suspect his rights. In police vernacular, he had been "Mirandized."
Impact
The importance of this case cannot be overstated. Denounced by presidents from Richard Nixon to Ronald Reagan, the Miranda decision has withstood all attempts to overturn it. Framed originally to protect the indigent and theignorant, the practice of "reading the defendant his rights" has become standard operating procedure in every police department in the country. The practice is seen so frequently in television police dramas that today the so-called "Miranda Warnings" are as familiar to most Americans as the Pledge of Allegiance.
Related Cases
- Chambers v. Florida, 309 U.S. 227 (1940).
- Mapp v. Ohio, 367 U.S. 643 (1961).
- Escobedo v. Illinois, 378 U.S. 478 (1964).
- Harris v. New York, 401 U.S. 222 (1971).
- Michigan v. Tucker, 417 U.S. 433 (1974).
- Rhode Island v. Innis, 446 U.S. 291 (1980).
Miranda Rights
In Miranda v. Arizona the Court established unequivocal protections that the accused was entitled to during interrogation "while in custody at thestation or otherwise deprived of his freedom of action in any significant way."
Miranda established that the accused must be informed that he or she has the right to remain silent and that if the suspect chooses not to remain silent that anything said can be used against the suspect in court. Before being interrogated the suspect must also be informed of the right to consult with an attorney, and to have legal counsel present during interrogation.
Additionally, the Miranda rule also requires that if the suspect is indigentthat he or she be informed that the court will provide counsel. If the suspect decides to remain silent, then the interrogation must end. Any statements obtained in violation of the suspects' Miranda rights are inadmissible as evidence in court. If the suspect decides to speak without consulting with an attorney then the prosecutor must prove that the suspect willingly waived Miranda rights.
Sources
Biskupic, Joan, and Elder Witt. Congressional Quarterly's Guide to the U.S. Supreme Court. Washington, DC: Congressional Quarterly, Inc., 1997.
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