Duckworth v. Eagan

On the surface, the issue under consideration appeared to center about whether police had to use specific language from the Miranda v. Arizona decision (1966) when advising suspects of their rights. The case at hand seemed to involve fairly routine consideration as to whether Indiana police appropriately advised the respondent of his Miranda rights in a clear manner. What transpired, however, was that four justices of the Court erupted into open conflict regarding the appropriateness of granting federal review to writs of habeas corpus for Miranda rights cases. Dissension, on the surface, centered about whether Miranda rights were properly served when the respondent was told he would be appointed an attorney "if and when" he went to court. But the most bickering centered around whether a previously decided case, Stone v. Powell, rendered what O'Connor characterized as "nonconstitutional" Miranda rights cases inappropriate for consideration beyond state-court level. (Scalia joined O'Connor who wrote a separate opinion siding with the majority while Brennan joined Marshall in the most contentious part of the minority opinion.) Marshall, not only challenged the wisdom of characterizing any cases involving personal rights as nonconstitutional, but he vehemently argued that Stone v. Powell was decided incorrectly in the first place. Disagreement among these four justices was contained, however, by Chief Justice Rehnquist's written decision. The majority opinion would contain discussion regarding Stone v. Powell by declaring the issue non-jurisdictional. Because none of the litigants had raised the issue of Stone v. Powell on certiorari, the Supreme Court was not bound to render any decision regarding extending that decision to contain constitutional Miranda rights appeals at state level. Thus, by not rendering a decision regarding Stone, the Court "chose" to reemphasize the importance of preserving federal litigation on federal habeas corpus of all Miranda rights cases.