Miranda v. Arizona
Supreme Court of the United States
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Miranda v. Arizona Supreme Court of the United States
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Plaintiff Ernesto Arturo Miranda was arrested for rape and was taken to the police station where he was interrogated for two hours. Under interrogation by the police, he admitted to charges of robbery and attempted rape. Miranda’s signed confession, which was later offered by the prosecutors as evidence during his trial along with the victim’s positive identification of Miranda as her assailant, stated that he voluntarily made it and that he had full knowledge of his legal rights. Miranda was convicted of rape and kidnapping and was sentenced to 20 to 30 years imprisonment on each charge, with sentences to run concurrently. Alvin Moore, Miranda’s court-appointed counsel, appealed to the Arizona Supreme Court which affirmed the conviction, emphasizing that Miranda did not specifically request counsel. Hence, this appeal to the Supreme Court of the United States.
Should law enforcement officers inform the accused of the latter’s constitutional rights? Are the statements obtained from an individual, who was subjected to custodial police interrogation, admissible if the former had not been notified of his right against self incrimination?
Under the fifth amendment’s self incrimination clause and the sixth amendment’s right to assistance of counsel, no confession can be admissible unless the accused has been informed of his rights and that the accused has waived them. When a person is taken into custody or otherwise deprived of his freedom, the following warning must be given: that he has the right to remain silent; that anything he says can be used against him in a court of law; that he has the right to have an attorney present; and that if he cannot afford one, one will be appointed for him.
The majority opinion penned by Chief Justice Warren, acknowledged that Miranda’s statements were not “involuntary in traditional terms.” However, the ponente also stated that the intimidating environment in which police interrogation takes place creates a strong potential for compulsion of confessions. As a result, “no statement obtained from the defendant can truly be the product of his free choice,” “unless adequate protective devices are employed.” The court required law enforcement officers to give the above mentioned warning, later on to be known as the Miranda Rights, to any person who is in custody or otherwise deprived of his freedom of action in any significant way. The accused may waive these rights only if they do so voluntarily, knowingly, and intelligently. In the case at bar, Miranda was not in any way notified of his rights which makes his confession inadmissible. His signing of a confession that stated that he had full knowledge of his legal rights is not a valid waiver either. The mere fact that he signed a statement which contained a typed-in clause stating that he had "full knowledge" of his "legal rights" does not approach the knowing and intelligent waiver required to relinquish constitutional rights.
Petition is granted. The conviction appealed from is reversed.
Point of View:
I agree with the majority decision. I believe that the confession of Miranda is in effect, involuntary, because of the intimidating atmosphere of the police interrogation. The nature of the investigation promotes the confession of the accused. Therefore, it can be likened to the practice of torturing suspects to obtain admissions of guilt. Also, the accused was not aware of his right against self incrimination when he signed the confession. In a constitutional nation, the right of the accused is given paramount importance. The warning prescribed by the Court to be given before questioning, ensures that the rights of the accused are protected.
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