The Miranda Decision
The Miranda decision was a consolidation of four different cases presenting the same legal question to the U.S. Supreme Court: whether custodial interrogation should be judged on a case-by-case basis for evidence of police coercion, or instead should require special procedural protections to ensure that confessions are voluntary. The facts of Ernesto Miranda’s case illustrated the point of this legal question.
In 1963, an 18-year-old woman was kidnapped and raped near Phoenix, Arizona. Ten days later, the police arrested Miranda and took him to the local police station. Miranda was 23 years old, poor, and educated only to the ninth grade. Miranda also suffered from an “emotional illness.”At the station, the victim was unable to positively identify Miranda, from a lineup, as her attacker. The police told Miranda otherwise, and took him to another room where two officers interrogated him in isolation.
During this interrogation, the police did not employ physical force, threats, or promises. But neither did the police advise Miranda of his right to have a lawyer present during the interrogation. Miranda at first denied his guilt. But after two hours, the police emerged with a signed written confession. This confession included a declaration that the confession “was made voluntarily, without threats or promises of immunity and ‘with full knowledge of my legal rights, understanding that any statements I make may be used against me.’” Miranda’s confession was admitted at his trial, and he was convicted and sentenced to prison.
In reviewing Miranda’s conviction, the Supreme Court acknowledged that Miranda’s statements were voluntary. Yet, the Court emphasized, “[t]he fact remains that in none of these cases did the officers undertake to afford appropriate safeguards at the outset of interrogation to insure that the statements were truly the product of free choice.” The four Miranda warnings, the Court ruled, supply these appropriate safeguards.
The Supreme Court thus pivoted in Miranda from a rule that merely prohibits coercive police conduct to a rule that requires the police to prevent coercion by giving a suspect specific legal warnings. This is the significance of Miranda. No longer were confessions admissible solely because the police abstained from bad behavior in securing the confession. Now, the police must affirmatively warn suspects of their right to remain silent and to have a lawyer. If the police do not give these warnings, a court will presume, solely from the lack of Miranda warnings, that the statement was involuntary and exclude it from trial.
The Supreme Court based the need for this protective rule in the nature of modern police interrogation. Modern interrogation practices, the Court observed, are “psychologically rather than physically oriented.” The goal is to isolate a suspect to deprive the suspect of every “psychological advantage” and “to subjugate the individual to the will of the examiner.” Indeed, “the very fact of custodial inter-rogation exacts a heavy toll on individual liberty and trades on the weakness of individuals,” and “is at odds with one of our nation’s most cherished principles—that the individual cannot be compelled to incriminate himself.” Only Miranda’s required warnings, the Court held, can dispel this inherent compulsion.
Excerpted from “Miranda v. Arizona: 50 Years of Judges Regulating Police Interrogation,” by Brooks Holland, which appeared in the Fall 2015 issue of Insights on Law & Society.