Robbery and Murder of a Providence Cab Driver

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Rhode Island v. Innis 446 U.S. 291 (1980)
Substantive Facts: Respondent was arrested on the night of January 12, 1975 for the robbery of Providence cab driver John Mulvaney, which lead to his murder. Mulvaney was shot in the head with a sawed-off shotgun, however no weapon was found present on the respondent at the time of his arrest. Upon the respondents’ arrest, respondent was informed of his Miranda rights by three police officers, to which he explained he understood those rights and wanted to speak with a lawyer. Officers then placed the respondent in the rear of a squad car containing the three aforementioned officers, one of which was seated in the rear with the defendant. Once en route to the police station, the officers began conversing about what a tragedy it would be if someone, namely a child who attended the nearby special education school, were to stumble upon the unaccounted weapon and harm themselves with it. Respondent then interrupted the officers’ conversation to divulge the location of the shotgun he had used in the crime in order to avoid the aforementioned accident from ever occurring.

Procedural Facts: Pre-trial, respondent moved to suppress the shotgun and statements he made regarding it. The Trial Court of Rhode Island denied the motion to suppress and allowed the shotgun and the statements to be presented. Respondent appealed his conviction of guilty on all counts, and the Rhode Island Supreme Court set aside the respondents’ conviction in addition to remanding the case for further proceedings not inconsistent with the court’s opinion and concluded Innis was entitled to a new trial.

ISSUE: Does the conversation between the officers in front of the respondent constitute an ‘interrogation’ in violation of the respondent’s undisputed rights defined in the Miranda opinion?

HOLDING: No. The conversation was found to not be an interrogation, and therefore the respondent’s Fifth Amendment rights as stated in the U.S....
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