Petitioner
State of Rhode Island
Respondent
Thomas J. Innis
Petitioner's Claim
That a conversation between two police officers with a murder suspect withinearshot did not constitute an interrogation in violation of the suspect's Miranda rights.
Chief Lawyer for Petitioner
Dennis J. Roberts II
Chief Lawyer for Respondent
John A. MacFadyen III
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart (writing for the Court), Byron R. White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall, John Paul Stevens
Place
Washington, D.C.
Date of Decision
12 May 1980
Decision
Suspect Thomas J. Innis was found to have not been interrogated by the police.
Significance
In Rhode Island v. Innis, the Supreme Court clarified the definition of interrogation as it relates to the Miranda rule, which prohibits police officers from interrogating suspects if they have requested legal representation.
The events in this case follow the death of a Providence, Rhode Island, taxidriver in a shotgun murder. Shortly after this murder, a second taxi driver was robbed by a man wielding a sawed-off shotgun. The taxi driver identified aphotograph of Thomas J. Innis as the man who attacked him. Soon after, a police officer spotted Innis, who was unarmed, on the street near a school for handicapped children. The officer arrested Innis and advised him of his Miranda rights. A group of other police officers arrived at the scene. Innis was advised of his Miranda rights two more times. He stated that he understood hisrights and wanted to speak with an attorney. The police captain had Innis placed in a police car to be driven to the central station. The captain instructed the three patrolmen in the car not to interrogate or intimidate Innis in any way.
On the way to the station, two of the patrolmen, Officers Gleckman and McKenna, began talking to each other about the missing shotgun. They expressed concern about whether one of the children might find the weapon the next morning."God forbid one of them might find a weapon with shells and they might hurtthemselves," said one of the officers. Innis interrupted the conversation, telling the officers he could lead them to the missing shotgun. The patrol carreturned to the scene of the arrest where Innis was once again advised of hisMiranda rights. He replied that he understood his rights and proceeded to show the policemen where the shotgun was located. Innis was subsequently put ontrial for kidnapping, robbery, and murder. In court, he tried to have the evidence of the shotgun and his statements to the police suppressed. The courtdenied this motion and convicted Innis. Upon his conviction, Innis appealed.
On appeal, the Rhode Island Supreme Court set aside the conviction. It held that the police officers in the patrol car had indeed interrogated Innis without first getting him to waive his right to a lawyer. This constituted a violation of the Miranda requirement that, in the absence of counsel, all "custodial interrogation" of a suspect must cease. The Court ordered a new trial. The state of Rhode Island appealed this decision and in 1979 the U.S. Supreme Court agreed to hear the case.
The Supreme Court Ruling
On 12 May 1980 the Supreme Court issued its decision. In a 6-3 vote, it vacated the ruling of the Rhode Island Supreme Court. Justice Stewart wrote the majority opinion, in which he was joined by Justices Blackmun, Rehnquist, Powell, and White. Chief Justice Burger concurred with the judgment but did not sign on with the majority opinion. Justices Marshall, Brennan, and Stevens dissented. Since all participants agreed that Innis had been read his Miranda rights, both the majority opinion and the dissents rested on the one central issue in the case, as stated by Justice Stewart:
In making its decision, the Court majority first had to establish a definition of "interrogation":
The Court then subjected the facts in the case to the legal test to determinewhether what happened to Innis was, in fact, an interrogation:
The Court went on to conclude that Innis was not even subjected to the "functional equivalent" of an interrogation because there was no way the officers could have known that he would respond to their conversation in the way that he did:
Rhode Island v. Innis was an important case in the clarification of the Miranda rule first set down in 1966. The majority opinion contained the Court's clearest definition of interrogation to date. To the dissenters, however, this decision represented an unnecessary narrowing of Miranda rights that rendered them all but meaningless.
Related Cases
State of Rhode Island
Respondent
Thomas J. Innis
Petitioner's Claim
That a conversation between two police officers with a murder suspect withinearshot did not constitute an interrogation in violation of the suspect's Miranda rights.
Chief Lawyer for Petitioner
Dennis J. Roberts II
Chief Lawyer for Respondent
John A. MacFadyen III
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Lewis F. Powell, Jr., William H. Rehnquist, Potter Stewart (writing for the Court), Byron R. White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall, John Paul Stevens
Place
Washington, D.C.
Date of Decision
12 May 1980
Decision
Suspect Thomas J. Innis was found to have not been interrogated by the police.
Significance
In Rhode Island v. Innis, the Supreme Court clarified the definition of interrogation as it relates to the Miranda rule, which prohibits police officers from interrogating suspects if they have requested legal representation.
The events in this case follow the death of a Providence, Rhode Island, taxidriver in a shotgun murder. Shortly after this murder, a second taxi driver was robbed by a man wielding a sawed-off shotgun. The taxi driver identified aphotograph of Thomas J. Innis as the man who attacked him. Soon after, a police officer spotted Innis, who was unarmed, on the street near a school for handicapped children. The officer arrested Innis and advised him of his Miranda rights. A group of other police officers arrived at the scene. Innis was advised of his Miranda rights two more times. He stated that he understood hisrights and wanted to speak with an attorney. The police captain had Innis placed in a police car to be driven to the central station. The captain instructed the three patrolmen in the car not to interrogate or intimidate Innis in any way.
On the way to the station, two of the patrolmen, Officers Gleckman and McKenna, began talking to each other about the missing shotgun. They expressed concern about whether one of the children might find the weapon the next morning."God forbid one of them might find a weapon with shells and they might hurtthemselves," said one of the officers. Innis interrupted the conversation, telling the officers he could lead them to the missing shotgun. The patrol carreturned to the scene of the arrest where Innis was once again advised of hisMiranda rights. He replied that he understood his rights and proceeded to show the policemen where the shotgun was located. Innis was subsequently put ontrial for kidnapping, robbery, and murder. In court, he tried to have the evidence of the shotgun and his statements to the police suppressed. The courtdenied this motion and convicted Innis. Upon his conviction, Innis appealed.
On appeal, the Rhode Island Supreme Court set aside the conviction. It held that the police officers in the patrol car had indeed interrogated Innis without first getting him to waive his right to a lawyer. This constituted a violation of the Miranda requirement that, in the absence of counsel, all "custodial interrogation" of a suspect must cease. The Court ordered a new trial. The state of Rhode Island appealed this decision and in 1979 the U.S. Supreme Court agreed to hear the case.
The Supreme Court Ruling
On 12 May 1980 the Supreme Court issued its decision. In a 6-3 vote, it vacated the ruling of the Rhode Island Supreme Court. Justice Stewart wrote the majority opinion, in which he was joined by Justices Blackmun, Rehnquist, Powell, and White. Chief Justice Burger concurred with the judgment but did not sign on with the majority opinion. Justices Marshall, Brennan, and Stevens dissented. Since all participants agreed that Innis had been read his Miranda rights, both the majority opinion and the dissents rested on the one central issue in the case, as stated by Justice Stewart:
The issue, therefore, is whether the respondent was "interrogated" by the police officers in violation of the respondent's undisputed right under Miranda to remain silent until he had consulted with a lawyer.
In making its decision, the Court majority first had to establish a definition of "interrogation":
[T]he term "interrogation" under Miranda refers not only to express questioning, but also to any words or actionson the part of the police (other than those normally attendant to arrest andcustody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.
The Court then subjected the facts in the case to the legal test to determinewhether what happened to Innis was, in fact, an interrogation:
Itis undisputed that the first prong of the definition of "interrogation" wasnot satisfied, for the conversation between Patrolmen Gleckman and McKenna included no express questioning of the respondent. Rather, that conversation was, at least in form, nothing more than a dialogue between the two officers towhich no response from the respondent was invited.
The Court went on to conclude that Innis was not even subjected to the "functional equivalent" of an interrogation because there was no way the officers could have known that he would respond to their conversation in the way that he did:
The case thus boils down to whether, in the context of a brief conversation, the officers should have known that the respondent would suddenly be moved to make a self-incriminating response. Given the fact that the entire conversation appears to have consisted of no more than a few offhandremarks, we cannot say that the officers should have known that it was reasonably likely that Innis would so respond.
Rhode Island v. Innis was an important case in the clarification of the Miranda rule first set down in 1966. The majority opinion contained the Court's clearest definition of interrogation to date. To the dissenters, however, this decision represented an unnecessary narrowing of Miranda rights that rendered them all but meaningless.
Related Cases
- Miranda v. Arizona, 384 U.S. 436 (1966).
- United States v. Henry, 447 U.S. 264 (1980).
- Edwards v. Arizona, 451 U.S. 477 (1981).
- Maine v. Moulton, 474 U.S. 159 (1985).
- Kuhlmann v. Wilson, 477 U.S. 436 (1986).
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