Miranda vs Arizona

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Robert Henry
Miranda v Arizona

“This Court has undertaken to review the voluntariness of statements obtained by police in state cases since Brown v. Mississippi, 297 U. S. 278 (1936). (Davis v. North Carolina, 384 U.S. 737 (1966))

The Warren Court from 1953 until 1969 established luminary rights with its liberal interpretation, and as some say “ judicial policy making”, such as the “right to privacy” Griswold v. Connecticut, 381 U.S. 479(1965), “separate but equal is not constitutional” Brown v. Board of Education, 347 U.S. 483 (1954) and the definitive protection of rights in the Miranda decision.

Miranda v. Arizona was one of a series of landmark Supreme Court cases of the mid-1960's establishing new guarantees of procedural fairness for defendants in criminal cases. The Court's decision in Miranda sprang from two different lines of precedents under the Fourteenth Amendment. One of these lines was the right-to-counsel cases: Powell v. Alabama (1932), in which the Court held that indigent defendants had to be afforded counsel in capital cases; Gideon v. Wainwright (1963), which extended the right to counsel for indigent defendants to all felony cases; and Escobedo v. Illinois (1964), in which the Court held that a confession obtained from a defendant who had asked for and been denied permission to speak to an attorney was inadmissible. By 1964, the right to counsel had expanded to include mandatory representation for indigents at trial in all felonies and also gave potential defendants the right to representation during questioning while in custody if they requested it.

The second line of cases culminated with Malloy v. Hogan (1964), in which the Court had held that the privilege against self-incrimination applied to the states. Moreover, prior to the Miranda case, a long series of Supreme Court decisions had established that neither physical coercion nor certain forms of psychological coercion could be used by police to obtain confessions from accused persons. Thus, on the eve of Miranda, constitutional rules barred the admission of confessions which had been coerced through either physical or psychological pressures or which had been obtained from an in-custody defendant who had requested the attendance of an attorney.

By then it was also clear that the entire body of the Fifth Amendment's self-incrimination clause was to be applied to the states through the due process clause of the Fourteenth Amendment. Like the other cases mentioned, Miranda rests on the due process clause of the Fourteenth Amendment, which requires that criminal procedure in state courts be fundamentally fair. (Baker)

Ernesto Miranda's case involved a confession to rape and kidnapping which was elicited from him in a police interrogation room after his arrest. In addition to his oral admissions to the investigating officers, Miranda wrote out by hand a short statement, which he signed. The questioning, by two Phoenix detectives, involved neither physical nor psychological coercion as these had been defined in the earlier cases. The transcript of Miranda's interview showed that he answered the officers' questions freely, and that after an initial denial, he readily admitted abducting the victim and raping her. The entire interrogation and the preparation of Miranda's written statement took less than two hours. Certiorari granted, U.S. Supreme Court

At trial, Miranda's oral admissions and his written statement were admitted into evidence over his objection; the victim testified against him as well. The jury found Miranda guilty of rape in the first degree and kidnapping, and he was sentenced to prison for a term of twenty to thirty years. He appealed to the Supreme Court of Arizona. After losing in that court, he appealed to the U.S. Supreme Court, which decided to hear the case in 1965. Miranda and three companion cases were argued February 28-March 2, 1966. On June 13, 1966, the Court decided in Miranda's favor by a 5-4 vote....
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