Rhode Island v. Innis

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, taxi driver 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 a photograph 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 his rights 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 hurt themselves," said one of the officers. Innis interrupted the conversation, telling the officers he could lead them to the missing shotgun. The patrol car returned to the scene of the arrest where Innis was once again advised of his Miranda rights. He replied that he understood his rights and proceeded to show the policemen where the shotgun was located. Innis was subsequently put on trial for kidnapping, robbery, and murder. In court, he tried to have the evidence of the shotgun and his statements to the police suppressed. The court denied 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.