Facts
- Ernesto Arturo Miranda was arrested in Phoenix, taken to a police station, identified by the victim, and interrogated for about two hours while in custody.
- Officers did not tell Miranda he had the right to remain silent or the right to have counsel present during questioning.
- Miranda signed a written confession after the interrogation.
- At trial, Miranda’s oral and written confessions were admitted; he was convicted of kidnapping and rape and sentenced to 20–30 years on each count.
- The Arizona Supreme Court affirmed, reasoning that Miranda had not requested counsel and that the confession was voluntary.
- The Supreme Court consolidated Miranda with three companion cases (Vignera, Westover, Stewart) involving confessions obtained during custodial interrogation without clear warnings and later admitted at trial.
Issues
- Whether the prosecution may use statements obtained during custodial interrogation when the suspect was not first clearly informed of Fifth Amendment rights and did not validly waive them.
- What procedures are required to protect the Fifth Amendment privilege against self-incrimination during custodial interrogation.
Decision
- The Supreme Court reversed Miranda’s conviction and held his confession inadmissible because it was obtained without required warnings and without a valid waiver.
- The Court held that the prosecution may not use statements stemming from custodial interrogation unless it shows effective safeguards protecting the Fifth Amendment privilege.
- The Court required, absent equally effective alternatives, that police give specific warnings before custodial questioning: the right to remain silent; that statements may be used in court; the right to consult with a lawyer and have the lawyer present; and the right to appointed counsel if indigent.
- The Court held that any waiver must be voluntary, knowing, and intelligent, and that the prosecution bears a heavy burden to prove warnings and waiver.
- If a suspect indicates a desire to remain silent, questioning must stop; if the suspect requests an attorney, questioning must stop until counsel is present.
- The Court vacated or reversed the companion case judgments to the extent they relied on unwarned custodial statements and remanded for further proceedings.
Legal Principles
- Custodial interrogation creates pressures that can compel self-incrimination; preventive safeguards are required to protect the Fifth Amendment privilege in that setting.
- Statements (inculpatory or exculpatory) obtained from custodial interrogation are inadmissible in the prosecution’s case-in-chief unless preceded by effective warnings and a valid waiver.
- Required warnings before custodial interrogation include: (1) right to remain silent; (2) notice that statements can be used against the suspect; (3) right to counsel during interrogation; (4) right to appointed counsel if indigent.
- A waiver of these rights is valid only if made voluntarily, knowingly, and intelligently; the government must prove waiver.
- Invocation rules: once the suspect invokes silence or requests counsel, interrogation must cease (and for counsel, may not resume until counsel is present).
Conclusion
The Court held that custodial interrogation requires specified warnings and a proven voluntary, knowing, and intelligent waiver as prerequisites to admitting a defendant’s statements, reversing Miranda’s conviction and directing similar treatment of related unwarned custodial confessions.