Berkemer v. McCarty
Were Mccarty's Rights Violated?
McCarty and his defense tried to have the court exclude the incriminating statements he made while in custody because the police never informed him of his constitutional rights before questioning him. The trial court rejected his request and McCarty pleaded "no contest," receiving a 90-day jail sentence and a $300 fine. The court reduced his penalty to 10 days in jail and a $200 fine. Nonetheless, McCarty appealed his sentence, maintaining that Trooper Williams violated his rights and that he failed the sobriety test because of a back injury and a limp leg, which made him look drunk or intoxicated. The Ohio Court of Appeals, however, argued that the Miranda warnings did not apply to misdemeanors in accordance with the State v. Pyle (1970) ruling. Furthermore, the Ohio Supreme Court refused to hear the case, believing that it did not raise a significant constitutional question. McCarty next petitioned the District Court for the Southern District of Ohio. The district court also dismissed McCarty's request, saying that the Miranda warnings did not apply to traffic arrests.
Finally, the Court of Appeals for the Sixth Circuit sided with McCarty, mandating that the police must provide Miranda warnings prior to any formal arrest, no matter what class of crime, including traffic violations. The court of appeals distinguished between the statements McCarty made before and after his arrest, ruling that those made after his arrest could clearly not be used against him. However, the ruling left some things unanswered, in particular, if all of McCarty's statements prior to his arrest could be used against him and which statements the court could use in McCarty's retrial.
The U.S. Supreme Court began hearing the case on 28 April 1984 in order to resolve the dispute surrounding Miranda warnings and minor violations such as traffic offenses and questioning motorists at traffic stops. Since the Fifth Amendment states that "no person . . . shall be compelled in any criminal case to be a witness against himself," state and federal law enforcement officers must ensure that suspects are aware that they are not obligated to answer their questions, especially if the information is self-incriminating. Out of concern for such situations, the Court decided in Miranda v. Arizona that police must inform all suspects of their rights prior to interrogating them.
Although the Franklin County police department argued for allowing them to use the evidence they obtained while questioning McCarty, the Court strongly disagreed, holding that the possibility of coercion and police manipulation of the confession applies just as much to misdemeanors as it does to felonies. The Court reasoned that not only can an interrogation for a misdemeanor escalate into one for a felony, but also the setting of police custody works "to undermine the individual's will to resist," as the Court decided in Miranda v. Arizona. Berkemer urged that providing Miranda rights for traffic arrests would impede and slow down law enforcement, but the Court rejected this argument, noting that traffic arrests and interrogations do not occur frequently and reading suspects their rights in such cases would not impose any extra burden since police are already accustomed to giving the Miranda warnings prior to all other interrogations in police custody.
The Court then tackled the more difficult question of the statements McCarty made while interrogated at the roadside. McCarty tried to persuade the Court that the Miranda warnings apply to these questionings as well, because he was "deprived of his freedom of action," as the Miranda decision stipulates, while Berkemer maintained that traffic stops lay outside Miranda's scope. The Court decided that since traffic stops usually are temporary and brief and since they typically are not that intimidating, Miranda warnings apply to formal arrests, not to routine traffic stop questioning. Consequently, the Court deemed McCarty's roadside statements admissible. However, the Court also found that if roadside questioning should evolve into more intense and vigorous interrogation, then the questioning should be considered interrogation in police custody and subject to all the Miranda warnings. The Court hoped this additional point would help avert police abuse of the roadside-questioning exemption to the Miranda warnings.
While all the justices agreed with most of the Court's decision, Justice Stevens felt the Court answered more than the case required. The Court's decision covered a broad range of issues surrounding Miranda warnings and Justice Stevens felt the decision resembled blanket legislation rather than resolving a specific legal dispute presented by the two parties. Nonetheless, resting on the distinction between questioning for a routine traffic stop and questioning while under arrest or in police custody, Ber kemer v. McCarty articulated the general circumstances in which the police need and need not provide motorists the Miranda warnings. "When the police arrest a person for allegedly committing a misdemeanor traffic offense and ask him questions without telling him his constitutional rights, petitioner argues, his responses should be admissible against him. We cannot agree."