In a 5-4 Supreme Court decision Miranda v. Arizona (1966) ruled that an arrested individual is entitled to rights against self-discrimination and to an attorney under the 5th and 6th Amendments of the United States Constitution. Miranda v. Arizona (1966) culminated in the famed “Miranda rights” requirement during arrests.
On March 13, 1963, police arrested Ernesto Miranda on charges of rape and kidnapping after a witness identified him in Phoenix, Arizona. During his two-hour interrogation, police did not advise Miranda on his constitutional rights to an attorney nor against self-incrimination. Nonetheless, he signed a written confession affirming knowledge of these rights and admitting to crimes. This confession led to a June 27, 1963 conviction of rape and kidnapping as well as a robbery pending on Miranda’s record. Judge McFate sentenced Miranda to a maximum fifty-five years in prison. Miranda’s lawyer, Alvin Moore, appealed the case to the Arizona Supreme Court, which reaffirmed the lower court’s decision, arguing that police had not violated Miranda’s constitutional rights in procuring a confession without the presence of a lawyer.
The Supreme Court ruled differently on June 13, 1966. It held that presenting Miranda’s confession as evidence violated his constitutional rights under the 5th and 6th Amendments. The 5th Amendment protects from self-incrimination and requires the police to inform the detainee about his or her rights while the 6th guarantees criminal suspects rights to a personal or state issued attorney. Chief Justice Earl Warren articulated that the court permitted confessions or self-incriminating statements in criminal trials only when suspects issued them deliberately after police inform of their rights. Miranda v. Arizona (1966) included four dissenters and three separate dissenting opinions.
After Arizona’s ruling was overturned, the state court retried the case without presenting Miranda’s confession. They convicted him of the same charges, and sentenced him to a maximum 30 years in prison. Four years after his release on parole, a killer, who did receive his Miranda rights, stabbed Miranda to death.
The Four Miranda Warnings
- You have the right to remain silent.
- Anything you say can and will be used against you in a court of law.
- You have the right to an attorney.
- If you cannot afford an attorney, one will be appointed for you.
Timeline
| Phoenix police arrest Miranda on charges of rape, kidnapping, and robbery. After two hours of questioning, Miranda signs a written confession. |
| The court denies Miranda legal representation at a preliminary hearing. |
| Alvin Moore appeals Miranda’s case to the Supreme Court of Arizona claiming his constitutional rights under the 5th and 6th Amendment had been violated. The state of Arizona reaffirms Miranda’s conviction. Miranda appeals to the U.S. Supreme Court. |
| The U.S. Supreme Court decides to hear Miranda’s case. |
| Lawyers argue Miranda v. Arizona before the Supreme Court. |
| Chief Justice Earl Warren delivers his decision, ruling Miranda’s confession is illegitimate and holding that Miranda’s constitutional rights under the 5th and 6th Amendment were violated. |
| Miranda’s second trial commences and lasts nine days. |
| Arizona jury finds Miranda guilty of rape, kidnapping, and robbery without his confession and the judge sentences him to a maximum 30 years in prison. |
| Miranda is released from prison on parole. |
| A killer, who receives his Miranda rights, stabs Miranda to death. |
Resources
Abstract
Miranda requires that police inform suspects of certain rights, such as the right to remain silent. From a fourth amendment standpoint, a stop to write a citation is not intrusive; thus, there is no 'custody' sufficient to give rise to Miranda rights. However, in all traffic encounters where a person is placed under arrest and removed involuntarily from the scene of the traffic stop, Miranda warnings must be given. A number of jurisdictions have reasoned that Miranda warnings are never required when a traffic offense is charged. Courts which extend the Miranda requirements to traffic offenses nonetheless distinguish between an investigatory stop and a custodial arrest. State courts have a duty under the supremacy clause to apply Miranda to all 'crimes' as that term has been interpreted under the fifth amendment. Miranda warnings will not interfere with police investigations because the rule should not apply to every stop to write a ticket but only to traffic arrests. Miranda safeguards should be available to every person, no matter how minor that person's crime. Footnotes are supplied.