Several different cases dealt with custodial interrogations in the Supreme Court’s decision in Miranda v. Arizona. In each case, the defendant was questioned by police officers, detectives, or a prosecuting attorney in a room that was cut off from the outside world. The defendant was not given a full and effective warning of his rights when the interrogation began. In all the cases, the questioning produced oral admissions and, in three of them, signed statements that were used in the trial.
Miranda v. Arizona: Miranda was arrested at his home and taken to a police station where he was identified by the complaining witness. He was then interrogated by two police officers for two hours before signing a written confession. At trial, the oral and written confessions were presented to the jury. Miranda was found guilty of kidnapping and rape. He was sentenced to 20-30 years imprisonment on each count. On appeal, the Supreme Court of Arizona held that Miranda’s constitutional rights were not violated in obtaining the confession.
Issues: Whether “statements obtained from an individual who is subjected to custodial police interrogation” are admissible against him in a criminal trial and whether “procedures which assure that the individual is accorded his privilege under the Fifth Amendment to the Constitution not to be compelled to incriminate himself” are necessary.
Supreme Court holding: The Court held that “there can be no doubt that the Fifth Amendment privilege is available outside of criminal court proceedings and serves to protect persons in all settings in which their freedom of action is curtailed in any significant way from being compelled to incriminate themselves.” As such, “the prosecution may not use statements stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.”
Follow-Up: Miranda v. Arizona: After Miranda’s conviction was overturned by the Supreme Court, the State of Arizona retried him. At the second trial, Miranda’s confession was not introduced into evidence. Miranda was once again convicted and sentenced to 20-30 years in prison.
Source: Miranda v. Arizona (1966)
Administrative Office of the U.S. Courts