Miranda v Arizona 1966

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Miranda v Arizona 1966

Petitioner: Ernesto Miranda

Respondent: State of Arizona

Petitioner's Claim: That the Fifth Amendment privilege against self-incrimination protects a suspect's right to be informed of his constitutional rights during police questioning and applies to the states through the Due Process Clause of the Fourteenth Amendment.

Chief Lawyer for Petitioner: John Flynn

Chief Lawyer for Respondents: Gary K. Nelson

Justices for the Court: Hugo Lafayette Black, William J. Brennan, Jr., William O. Douglas, Abe Fortas, Earl Warren

Justices Dissenting: Tom C. Clark, John Marshall Harlan II, Potter Stewart, Byron R. White

Date of Decision: June 13, 1966

Decision: The Fifth Amendment protection from self-incrimination requires that suspects be informed of their constitutional rights before questioning by the police when they are in police custody.

Significance: Few events have altered the course of American criminal law more than the events surrounding the 1963 rape conviction of Ernesto Miranda. The only strong evidence against him was a confession he made while in police custody. The events surrounding that confession captured the nations attention and prompted a landmark United States Supreme Court decision.

In Phoenix, Arizona, during the early hours of March 3, 1963, an eighteen-year-old movie theater attendant was kidnapped by a stranger while on her way home from work. The stranger dragged her into his car, drove out into the desert, and raped her. Afterwards, he dropped her off near her home.

The young woman's story of the events was vague and confusing. She described her attacker as a Mexican in his late twenties wearing glasses. He drove an early 1950s car, either a Ford or Chevrolet.

By chance, one week later, the woman and her brother-in-law saw what she believed was the car of her attacker, a 1953 Packard, license plate number DFL-312. License records showed that this plate was actually registered to a late model Oldsmobile. But plate number DFL-317 was a Packard, registered to a woman, Twila N. Hoffman. Further investigation showed that her boyfriend, Ernesto Miranda, age twenty-three, fit the attacker's description almost exactly.

Ernesto Miranda had a long history of criminal behavior. He had served a one-year jail term for attempted rape. Police put him into a lineup with three other Mexicans of similar height and build, though none wore glasses. The victim did not positively identify Miranda, but told detectives that he looked most like her attacker.

Detectives Carroll Cooley and Wilfred Young took Miranda into another room for questioning. They told him, incorrectly, that the victim had identified him as her attacker from the line-up. They asked him to make a statement. Two hours later, Ernesto Miranda signed a written confession. He was not forced to sign the statement. The detectives did not physically or verbally abuse him. The confession even included a section stating that he understood his rights.

Miranda was given a lawyer, appointed by the court, to represent him because he did not have enough money to hire his own attorney. His lawyer, Alvin Moore, studied the evidence against Miranda. The case against him was very strong, with the most damaging evidence being his confession to the crime. Moore found the events surrounding the statement troubling. Convinced it had been obtained improperly, he intended to ask the court suppress this evidence and not permit his admission of guilt to come into evidence and be heard by the jury.

Only four witnesses appeared to testify for the prosecution: the victim, her sister, and Detectives Cooley and Young. In his closing argument to the jury, the prosecutor, Deputy County Attorney Laurence Turoff, told the jury that Ernesto Miranda, by the use of force and violence, raped the victim.

In Miranda's defense, Attorney Moore was able to point out several inconsistencies in the victim's story, including the fact that she had no physical injuries after her supposed attack. In his cross-examination of Detective Cooley, Attorney Moore made his most important point:

Question: Officer Cooley, in the taking of this statement, what did you say to the defendant to get him to make this statement?
Answer: I asked the defendant if he would . . . write the same story that he just told me, and he said that he would.
Question: Did you warn him of his rights?
Answer: Yes, sir, at the heading of the statement is a paragraph typed out, and I read this paragraph to him out loud.
Question: I don't see in the statement that it says where he is entitled to the advice of an attorney before he made it.
Answer: No, sir.
Question: Is it not your practice to advise people you arrest that they are entitled to the services of an attorney before they make a statement?
Answer: No, sir.

Based on this testimony, Moore asked the judge to keep the jury from hearing Miranda's confession. Judge Yale McFate overruled him. The judge gave the jury a well-balanced and fair account of the law as it stood at the time and permitted them to hear the confession. In 1963, the law did not include a constitutional right to remain silent at any time before the beginning of a trial.

Consequently, on June 27, 1963, Ernesto Miranda was convicted of both crimes and sentenced to two concurrent sentences of twenty-to-thirty years imprisonment. Concurrent sentences run at the same time.

However, Alvin Moore's arguments about the confession touched off a legal debate. Miranda's conviction was appealed all the way to the U.S. Supreme Court. On June 13, 1966, Chief Justice Earl Warren, writing the decision for a 5–4 majority, established guidelines about what is and what is not acceptable police behavior in an interrogation:

Prior to any questioning, the person must be warned that he has a right to remain silent, that any statement he does make may be used as evidence against him, and that he has a right to the presence of an attorney, either retained or appointed . . .

INFLUENTIAL CHIEF JUSTICE

E arl Warren was Chief Justice of the U.S. Supreme Court from 1953 to 1969. During this time, the "Warren Court" made some of the most influential decisions in modern U.S. history, establishing many civil rights and individual liberties issues. No one expected such landmark decisions from Warren whose previous history was as a rather unremarkable Republican politician. Warren was California's attorney general from 1939 to 1943 and its governor from 1943 to 1953, involving himself in a shameful chapter in the state's history. As attorney general during World War II, he pressed for the internment of Japanese Americans in detention camps, based on the fear that they might be enemy agents and spies. As governor, he presided over the internment process. In 1948, he was an unsuccessful vice-presidential candidate, running with Republican Thomas Dewey against President Harry S Truman. Yet as Chief Justice, Warren led the court to establish new precedents that outlawed school segregation, established the right to court-appointed attorneys, and asserted the right of arrested men and women to know their rights. While serving as Chief Justice, Warren also headed the "Warren Commission," established by President Lyndon Johnson on November 29, 1963, to investigate the assassination of President John F. Kennedy.

With Miranda's conviction overturned, the State of Arizona was forced to free its now famous prisoner. Without his confession, the state stood little chance of getting a second conviction.

It was Ernesto Miranda himself who brought about his own downfall. He expected to be released after the Supreme Court decision so he had begun a battle for custody of his daughter with Twila Hoffman, his common-law wife. A common-law marriage is an informal marriage where the couple has no license or ceremony but live together, with the intent to be married and tell others that they are married. Hoffman, angry and fearful, told authorities about a conversation with Miranda after his arrest, in which he had admitted the rape. This new evidence was all Arizona needed.

Miranda's second trial began February 15, 1967. Most of the arguments took place in the judge's private chambers. This time the main issue was whether Hoffman, his common-law wife could testify against Miranda, her common-law husband. Judge Lawrence K. Wren ruled that Hoffman's testimony could be allowed as evidence and Hoffman was allowed to tell her story to the jury. Miranda was convicted for a second time and sentenced him to twenty-to-thirty-years in jail.

On January 31, 1976, four years after his released from prison on parole, Ernesto Miranda was stabbed to death in a bar fight. The killer fled but his accomplice (helper) was caught. Before taking him to police headquarters for questioning, the arresting officers read the suspect his "Miranda rights."

The importance of this case cannot be overstated. Although presidents from Richard Nixon to Ronald Reagan have publicly disagreed with it, the Miranda decision remains law. Originally intended to protect the poor and the ignorant, the practice of "reading the defendant his rights" has become standard procedure in every police department in the country. The practice is seen so frequently in police movies and shows that the Miranda warnings are as familiar to most Americans as the Pledge of Allegiance.