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Miranda v. Arizona

Supreme Court of the United States · 1966 · Criminal Procedure

Criminal ProcedureFifth Amendmentself-incriminationcustodial interrogationMiranda warningsright to counselvoluntarinesscoerced confessions

Facts

The cases before the Court involved defendants who made statements or confessions while in police custody during interrogation. The majority adopted a rule requiring specified warnings and a clear waiver before such statements could be used. This opinion rejects the proposition that custody and questioning alone amount to compulsion under the Fifth Amendment. Justice White emphasized that some statements may be spontaneous and that, under prior cases, the admissibility question had turned on whether the defendant's will was overborne under the totality of the circumstances.

Issue

Does the Fifth Amendment forbid the use of statements obtained through in-custody police interrogation unless police first give specified warnings and obtain a clear waiver of counsel? Or does the Constitution instead permit custodial interrogation so long as the resulting statement is voluntary under the traditional totality-of-the-circumstances test?

Rule

Under the rule described in this opinion, the Fifth Amendment bars only compelled self-incrimination, not all statements made during custodial interrogation. Custody and police questioning do not by themselves make a statement involuntary; the proper inquiry is whether, under the totality of the circumstances, physical or psychological coercion deprived the accused of a free choice to admit, deny, or refuse to answer, or overbore his will.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Denver police arrested Luis Navarro outside his apartment on suspicion of burglary and brought him to the station. Ten minutes later, an officer asked, "Did you enter the warehouse on Grant Street?" Luis immediately answered, "Yes, I did," and there is no evidence of threats, promises, prolonged questioning, or isolation.

Under the approach described in this opinion, which is the best analysis of the admissibility of Luis's statement?

Explanation. This opinion rejects a per se rule that custody and questioning alone amount to compulsion. Instead, the court asks whether, under the totality of the circumstances, physical or psychological coercion overbore the suspect's will or deprived him of a free choice to admit, deny, or refuse to answer. A brief custodial question without threats, promises, or other coercive circumstances would not be automatically excluded under this approach. (Derived from Miranda v. Arizona (1966).)