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Rhode Island v. Innis

Supreme Court of the United States · 1980 · Criminal Procedure

Criminal ProcedureFifth AmendmentMirandainterrogationfunctional equivalentcustodial interrogationcustodyright to counsel

Facts

After being arrested in connection with a robbery and advised several times of his Miranda rights, the respondent said he wanted to speak with a lawyer. While officers transported him to the police station, two officers talked to each other about the missing shotgun and expressed concern that a handicapped child from a nearby school might find it and get hurt. The officers did not directly question the respondent, but he interrupted and said they should turn around so he could show them where the gun was. After being advised again of his rights, he led police to the shotgun.

Issue

Whether the respondent, who was in custody and had invoked his Miranda right to counsel, was nevertheless "interrogated" when officers in his presence discussed among themselves the danger that a child might find the missing shotgun.

Rule

Under Miranda, "interrogation" refers not only to express questioning, but also to its functional equivalent: any words or actions by police, other than those normally attendant to arrest and custody, that the police should know are reasonably likely to elicit an incriminating response from the suspect. The inquiry focuses primarily on the suspect's perceptions, though police intent may bear on whether officers should have known their conduct was reasonably likely to produce such a response.

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

In Phoenix, police arrested Devin Porter for arson, advised him of his Miranda rights, and Devin said he wanted a lawyer before speaking. While waiting in an interview room, Detective Lara told Devin, "Tell me where you bought the gasoline, and maybe we can stop this from happening again." Devin then identified the gas station.

Was Devin subjected to interrogation for Miranda purposes?

Explanation. Interrogation under Miranda includes express questioning. Once a suspect in custody invokes the right to counsel, questioning must cease. The detective directly addressed Devin and sought information reasonably capable of incriminating him. Under the majority's rule, that is interrogation regardless of whether the officer also had some other motive. Police intent may be relevant, but the definition is not limited to conduct undertaken with a confessed intent to extract a confession.