## Facts

- Willie Thomas Butler was arrested on a federal warrant and questioned while in custody.
- An FBI agent orally advised Butler of his Miranda rights and provided an “Advice of Rights” form containing both warnings and a waiver clause.
- Butler read the form, stated he understood his rights, and refused to sign the waiver portion.
- Butler stated, in substance, that he would talk but would not sign anything.
- Butler did not request counsel and did not attempt to terminate the interrogation.
- Butler made incriminating statements that were admitted at his North Carolina trial, resulting in convictions for kidnapping, armed robbery, and felonious assault.
- The North Carolina trial court denied suppression, finding Butler had effectively waived his right to counsel.
- The Supreme Court of North Carolina reversed, adopting a rule that custodial statements are inadmissible absent an explicit waiver of counsel.
- The U.S. Supreme Court granted certiorari.

## Issues

1. Whether Miranda renders custodial statements inadmissible whenever there is no express (written or oral) waiver of rights.
2. Whether a Miranda waiver may be inferred from a suspect’s words and conduct under the totality of the circumstances.

## Decision

- The Court vacated the judgment of the Supreme Court of North Carolina and remanded.
- The Court held that an explicit statement of waiver is not invariably necessary to support a finding of waiver.
- The Court rejected the state court’s per se rule requiring an express waiver as a matter of federal constitutional law.
- The Court did not decide whether Butler actually waived his rights, leaving that determination for the state courts under the proper standard.

## Legal Principles

- Miranda requires the government to demonstrate a voluntary, knowing, and intelligent waiver, but it does not require waiver to take any particular form.
- A waiver may be inferred from the actions and words of the person interrogated, evaluated under the particular facts and circumstances, including the accused’s background, experience, and conduct.
- An express written or oral waiver is strong evidence of validity, but is neither always necessary nor always sufficient.
- Waiver cannot be presumed from a silent record; silence alone does not establish waiver, though silence combined with understanding and conduct indicating waiver may support a finding.
- A state court may not add to or subtract from federal constitutional requirements when stating what the U.S. Constitution demands for Miranda waiver.

## Conclusion

The Court held that Miranda does not impose an inflexible requirement of an express waiver; instead, waiver can be inferred from a suspect’s understanding and conduct, and the state court was required to reassess admissibility using that totality-of-the-circumstances standard.


North Carolina v. Butler, 441 U.S. 369 (1979)