## Facts

- Randall James Prysock, a 16-year-old, was taken into custody by Tulare County officers as a suspect in a murder.
- After being advised of his Miranda rights, he initially declined to speak.
- When his parents arrived, he agreed to a recorded interrogation in their presence.
- Before the recorded questioning, an officer again warned Prysock that he had the right to remain silent, that statements could be used against him, and that he had the right to consult with a lawyer before questioning and to have a lawyer present during questioning.
- The officer also advised that Prysock had the right to have a lawyer appointed at no cost, with that statement occurring after an intervening explanation of his right to have his parents present.
- The trial court denied a motion to suppress and Prysock was convicted of first-degree murder and other charges.
- A state intermediate appellate court reversed, ruling the warnings defective because they did not clearly state that appointed counsel would be available before and during interrogation.
- The state supreme court denied review, and the U.S. Supreme Court granted certiorari.

## Issues

1. Whether Miranda requires warnings to use the precise phrasing and sequence stated in Miranda v. Arizona.
2. Whether warnings are constitutionally insufficient when the advisement about appointed counsel comes after the advisement about consulting with counsel before and during questioning.

## Decision

- The Supreme Court reversed the state appellate court and remanded.
- The Court held Miranda does not impose a rigid requirement that warnings be a verbatim recitation or follow a fixed order.
- The Court concluded the warnings, read together, adequately conveyed the right to counsel, including appointed counsel if indigent, prior to and during interrogation.

## Legal Principles

- Miranda compliance turns on whether the warnings reasonably convey the required rights, not on exact language or a required sequence.
- A warning is not invalid merely because the statement about appointed counsel is separated from, or follows, statements describing the right to consult with counsel before and to have counsel present during interrogation.
- Courts should assess the full set of warnings for any suggestion that appointed counsel is available only after interrogation or only at trial; absent such a suggestion, the warnings may satisfy Miranda.

## Conclusion

The Court held that Miranda warnings are adequate if they reasonably communicate the rights to silence and to counsel, including appointed counsel before and during questioning, even when the warnings do not track Miranda’s exact wording or order.


California v. Prysock, 453 U.S. 355 (1981)