Miranda versus Dickerson
The United States Supreme Court is, for all intents and purposes, the final authority on legal matters regarding the federal or state governments. Additionally, the Supreme Court asks as the determining body to the constitutionality of laws made by either the federal or state governments. As such an authority, the Supreme Court is often faced with cases that emulate previous cases. At times the Court upholds its decisions, often times due to the concept of stare decisis or precedence, and other times the Court reverses its opinion. The most common reasons that the Court may overturn its decisions include: a shift if the ideology of the court, a shift in the political climate of the United States, or a change in the social culture has rendered a law or previous decision ineffective. Despite the list of possible motivators for the Court to reverse a decision, it is still uncommon to do so. Many of the factors that could contribute to a decision reversal also have the potential to be the reason the Court upholds a law.
An example of such a pairing of cases is Miranda v. Arizona (1965) and Dickerson v. United States (1999). The question posed in Miranda: are law enforcement agencies permitted to interrogate suspect without notifying the suspect of their right to counsel? Following this decision the argument rose in Dickerson, some 34 years later: can congress, by way of legislation, overrule the Miranda warnings to allow those statements that would be inadmissible otherwise? As expected the Court upheld its decision to utilize the warnings prior to interrogation suspects. However, the reasoning is more complex than mere stare decisis. An investigation into each case, their arguments, and the opinions as they were written may further expound upon the issue. Miranda v. Arizona
Prior to the Miranda case, the Warren Court made decisions regarding the Fifth and Sixth Amendments that forecasted their direction in Miranda. The most notable case that laid foundation for the decision in Miranda is Gideon v. Wainwright. This is the landmark case that led to the establishment of the public defender program in the United States. Another case is Massiah v. United States, which the Court established a test that provides suspects protection from self –incrimination once the Sixth Amendment right to counsel has been enacted. Another landmark case which gave insight to the climate of the Warren Court in regards to defendants’ rights is Escobedo v. Illinois. The decision in Escobedo determined that the Sixth Amendment right to counsel begins at the accusatory stage of police investigation. Given the decisions of Massiah, Escobedo, and Gideon, the stage was properly set for the Ernesto Miranda’s day in court.1 In 1963, Ernesto Miranda was taken into custody as a suspect in the rape and kidnapping of a 17 year old girl. While in custody, Miranda was interrogated by police for hours until he signed a written confession. Not once during the interrogation was Miranda informed of his rights to counsel or to remain silent. During the trial his court appointed attorney objected to the admission of the statement on the grounds that Miranda was not informed of his rights. Given the amount of evidence, including the confession itself, the court overruled the objection. After being found guilty and sentenced to 20-30 years in prison for his crimes, Miranda appealed to the Arizona Supreme Court. Due to the fact that Miranda failed to specifically request an attorney, the Arizona Supreme Court upheld the trial court’s decision. The case was then forwarded to the Supreme Court along with Westover v. United States, Vignera v. New York, and California v. Stewart.2 The Decision
The decision, delivered by Chief Justice Warren, was in favor of Miranda. The Court held that an individual in a state where his or her freedom is restricted by an agent of the law, police officer or detective, must be afforded the opportunity to...
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