Before trial on federal criminal charges, Dickerson sought to suppress a statement he made at an FBI field office. The lower courts agreed that he had not received Miranda warnings before being interrogated. The court of appeals nevertheless held the statement admissible because § 3501 made voluntariness the sole touchstone and concluded Miranda was not a constitutional holding. The Supreme Court addressed whether Congress could displace Miranda through § 3501.
Issue
May Congress, through 18 U.S.C. § 3501, replace Miranda's warning-based admissibility rule for statements made during custodial interrogation with a voluntariness test? More specifically, is Miranda a constitutional rule that Congress cannot legislatively supersede?
Rule
Miranda and its progeny govern the admissibility of statements made during custodial interrogation in both state and federal courts. Because Miranda announced a constitutional rule, Congress may not supersede it by statute; a statute that reinstates voluntariness alone as sufficient cannot displace Miranda's warning requirement.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Congress enacts the Custodial Statement Reliability Act, providing that in all federal prosecutions a defendant's statement made during custodial interrogation is admissible if the trial judge finds it voluntary under the totality of the circumstances, whether or not officers gave prequestioning warnings. In a federal robbery trial in Denver, prosecutors seek to introduce Noah Bennett's unwarned but concededly voluntary custodial confession in their case in chief.
How should the federal trial court rule on the statute's effect?
Explanation. The governing rule is that Miranda and its progeny govern admissibility of statements made during custodial interrogation in both state and federal courts, and Congress may not legislatively supersede that constitutional rule by restoring voluntariness alone as the test. A statute that makes voluntariness sufficient, while omitting a warning requirement, conflicts with Miranda and must yield.