Orzoco v. Texas

In a 5-2 decision, the U.S. Supreme Court reversed Orzoco's conviction. The Supreme Court disagreed with the state courts' conclusion that Miranda did not apply to bar admission of incriminating statements made by a suspect to police during questioning in the suspect's home. The Supreme Court held that Miranda applied to the questioning of Orzoco in his own home because the petitioner was "in custody," and that the use of statements obtained in the absence of the required Miranda warnings was a "flat violation of the Self-Incrimination Clause of the Fifth Amendment as construed in Miranda."

Acknowledging that some of the language in the Miranda decision suggested that the Court had viewed interrogation of a suspect in a police station as particularly susceptible to police intimidation or trickery, the Supreme Court refused to limit the Miranda rule to questioning of suspects by police in police stations. The Court instead emphasized the language of the Miranda opinion which "iterated and reiterated the absolute necessity for officers interrogating people `in custody' to give the described warnings." According to the Supreme Court, Miranda declared that the warnings were required when the person being interrogated was "in custody at the station or otherwise deprived of his freedom of action in any significant way." In this case, the record was clear that the petitioner was under arrest and not free to leave from the time the police officers entered his boarding house bedroom at 4:00 A.M.

Justice Harlan wrote a concurring opinion in which he disagreed with, but reluctantly acquiesced in the majority's reversal of the conviction. Justice Harlan had dissented in Miranda v. Arizona and still found the Miranda decision unpalatable. However, he felt compelled by the principle of stare decisis to concur in the reversal. Stare decisis refers to the principle of precedent, which requires judges to decide their cases by following the principles that previous judges have established in similar cases, even if they disagree with the established principles. To emphasize his reluctance in agreeing with the reversal, Justice Harlan stated in his concurrence that "the constitutional condemnation of this perfectly understandable, sensible, proper, and indeed commendable piece of police work highlights the unsoundness of Miranda."

In a dissenting opinion, Justices White and Stewart opposed the extension of Miranda to instances of in-custody questioning outside of police stations. Justices White and Stewart had dissented in the original Miranda ruling and viewed it as a "constitutional straitjacket" on law enforcement "which was justified neither by the words or history of the Constitution, nor by any reasonable view of the likely benefits of the rule as against its disadvantages." However, even accepting the original Miranda rule, the justices concluded that the Orozco majority had taken the rule to a "new and unwarranted extreme" by applying the rule to questioning outside of police stations. The dissenting justices believed that the purpose of the Miranda rule was to guard against "incommunicado interrogation of individuals in a police-dominated atmosphere" using such techniques as extended periods of isolation, repeated interrogation, cajolery, and trickery. The dissenting justices criticized the majority for ignoring the question "whether similar hazards exist or even were possible when police arrest and interrogate on the spot, whether on the street corner or in the home." Moreover, the dissent concluded that, in this case, there was "no prolonged interrogation, no unfamiliar surroundings, no opportunity for the police to invoke those procedures which moved the majority in Miranda."