Wainwright v. Greenfield
Facts
Respondent was charged with sexual battery and pleaded not guilty by reason of insanity. After his arrest, officers repeatedly gave him Miranda warnings, and each time he said he understood his rights but did not want to answer questions and wanted to speak with an attorney first. At trial, the prosecution introduced the officers' testimony about respondent's refusals to speak and, in closing argument, urged the jury to treat those refusals as evidence that respondent was sane because they showed comprehension inconsistent with insanity. The jury convicted respondent.
Issue
Does the Due Process Clause, as construed in Doyle v. Ohio, forbid the State from using a defendant's postarrest, post-Miranda silence as affirmative evidence of sanity after the defendant pleads insanity?
Rule
It violates due process for the State to use a defendant's postarrest, post-Miranda silence against him at trial, because Miranda warnings implicitly assure that the exercise of the right to remain silent will not be penalized. That principle applies not only when silence is used to impeach trial testimony, but also when silence is used as evidence to rebut a plea of insanity and prove sanity.
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Was the prosecutor's use of Omar's silence most likely permissible?