Doyle v. Ohio

A person's right to due process, including the right to remain silent after arrest without later penalty, was preserved in this case.

Thanks to film and television shows on crime, most people are familiar with the term "Miranda rights." This refers to the case of Miranda v. Arizona (1966) in which the rights of a person to due process under the law were established. According to these rights, when an individual is arrested, he must be advised immediately that he has the right to remain silent, that anything he says may be used against him, and that he has a right to legal counsel before answering questions. In the case of Doyle v. Ohio and a corresponding case, Wood v. Ohio, these rights were under review by the courts.

In Tuscarawas County, Ohio, Jefferson Doyle and Richard Wood were arrested and charged with selling ten pounds of marijuana to a local narcotics bureau informant. Upon arrest, they were both given Miranda warnings and stayed silent after receiving them. However, during their trial, the two men both testified that they had been framed by the narcotics agents. The state's accounts of the transaction differed from the defendants in that the state alleged that the defendants were selling the marijuana to the informant, whereas the defendants alleged that the informant was selling marijuana to the defendants. The defense argued that because there was a limited view of the parking lot where the transaction supposedly took place, the narcotics agents did not actually see the transaction take place. Both stories were plausible, without direct evidence to contradict it.

In both cases, the prosecutor, in order to cast doubt on their testimony, questioned them as to why they did not provide this account at the time of their arrest. Although their defense attorneys objected to the prosecutor's line of questioning, the trial court judge overruled them and Doyle and Wood admitted that they had remained silent. The two men were both convicted in the Common Pleas Court of Tuscarawas County.

Both cases were appealed to the Court of Appeals of the Fifth District, Tuscarawas County on the basis that the trial court should not have allowed the prosecutor's line of questioning. The appeals court agreed with the trial court's decision, noting that the questioning "was not evidence offered by the state in its case . . . as confession by silence or as substantive evidence of guilt but rather cross examination of a witness as to why he had not told the same story earlier at his first opportunity." The defendants then appealed to the Ohio Supreme Court which refused to review the case further. Finally, the appellants asked the U.S. Supreme Court to review the case, also known as taking the case on certiorari.

On 17 June 1976, the Supreme Court reversed the men's convictions and returned the cases to the Ohio State courts for further action. In a 6-3 decision, Justice Powell delivered the opinion for the majority. The relatively brief decision stated that the prosecutor's use of the defendants' silence following their arrest violated their right to due process. The support for this argument was that silence following arrest was only the individual's exercise of their Miranda rights which makes its intent or meaning indefinite. In addition, although the Miranda rights do not say explicitly that a person's silence will not be penalized later, that assurance is implicit. Because of this, it is a violation of due process to allow the person's silence to be used to question an explanation later offered at the trial. In essence, the Court preserved an individual's right to due process under the law.