Rhode Island v. Innis
The Supreme Court Ruling
On 12 May 1980 the Supreme Court issued its decision. In a 6-3 vote, it vacated the ruling of the Rhode Island Supreme Court. Justice Stewart wrote the majority opinion, in which he was joined by Justices Blackmun, Rehnquist, Powell, and White. Chief Justice Burger concurred with the judgment but did not sign on with the majority opinion. Justices Marshall, Brennan, and Stevens dissented. Since all participants agreed that Innis had been read his Miranda rights, both the majority opinion and the dissents rested on the one central issue in the case, as stated by Justice Stewart:
The issue, therefore, is whether the respondent was "interrogated" by the police officers in violation of the respondent's undisputed right under Miranda to remain silent until he had consulted with a lawyer.
In making its decision, the Court majority first had to establish a definition of "interrogation":
[T]he term "interrogation" under Miranda refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect.
The Court then subjected the facts in the case to the legal test to determine whether what happened to Innis was, in fact, an interrogation:
It is undisputed that the first prong of the definition of "interrogation" was not satisfied, for the conversation between Patrolmen Gleckman and McKenna included no express questioning of the respondent. Rather, that conversation was, at least in form, nothing more than a dialogue between the two officers to which no response from the respondent was invited.
The Court went on to conclude that Innis was not even subjected to the "functional equivalent" of an interrogation because there was no way the officers could have known that he would respond to their conversation in the way that he did:
The case thus boils down to whether, in the context of a brief conversation, the officers should have known that the respondent would suddenly be moved to make a self-incriminating response. Given the fact that the entire conversation appears to have consisted of no more than a few offhand remarks, we cannot say that the officers should have known that it was reasonably likely that Innis would so respond.
Rhode Island v. Innis was an important case in the clarification of the Miranda rule first set down in 1966. The majority opinion contained the Court's clearest definition of interrogation to date. To the dissenters, however, this decision represented an unnecessary narrowing of Miranda rights that rendered them all but meaningless.