Ernesto Miranda was arrested in Arizona for kidnapping and rape and was taken to a police station for questioning. After about two hours of custodial interrogation, he signed a written confession. Before questioning, police did not inform him that he had a right to remain silent, that anything he said could be used against him, or that he had a right to counsel, retained or appointed. His confession was introduced at trial, and he was convicted.
Does the Fifth Amendment permit prosecutors to use statements from custodial interrogation when police did not first warn the suspect of the rights to remain silent and to counsel?
The Fifth Amendment privilege against self-incrimination applies to custodial police interrogation. Before questioning, law enforcement must warn a suspect that he has the right to remain silent, that anything said can be used against him, that he has the right to an attorney, and that if he cannot afford one, one will be appointed; statements obtained without these safeguards are generally inadmissible in the prosecution's case-in-chief.
No. Statements obtained from a suspect during custodial interrogation are inadmissible unless procedural safeguards effective to secure the privilege against self-incrimination are used, including the now-required Miranda warnings and a knowing, voluntary, and intelligent waiver.
The Court reasoned that custodial interrogation is inherently coercive because isolation and police-dominated questioning create pressures that can undermine a suspect’s free choice to speak or remain silent. Existing voluntariness doctrine was deemed insufficient to protect the Fifth Amendment privilege in that setting. The warnings and waiver requirement were adopted as concrete procedural safeguards to dispel compulsion and ensure any statement is truly the product of free choice. Because Miranda was not adequately advised of his rights before interrogation, his confession could not be used against him.
Justice Harlan, joined by Justices Stewart and White, argued the Constitution did not require the Court’s detailed warning-and-waiver code and that the decision departed from precedent by imposing rigid rules not found in the Fifth Amendment’s text. Justice White separately warned that the ruling would unduly hamper law enforcement and exclude reliable confessions.
Miranda is a foundational criminal procedure decision that constitutionalized warning requirements for custodial interrogation and made "Miranda warnings" a standard feature of American policing. It built on Escobedo v. Illinois, 378 U.S. 478 (1964), and was later limited and elaborated in cases such as Harris v. New York, 401 U.S. 222 (1971) (impeachment use), Edwards v. Arizona, 451 U.S. 477 (1981) (post-invocation questioning), New York v. Quarles, 467 U.S. 649 (1984) (public safety exception), Dickerson v. United States, 530 U.S. 428 (2000) (Miranda as a constitutional rule Congress could not overrule by statute), and Berghuis v. Thompkins, 560 U.S. 370 (2010) (invocation and implied waiver).
Escobedo v. Illinois, 378 U.S. 478 (1964) |
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Harris v. New York, 401 U.S. 222 (1971) |
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Edwards v. Arizona, 451 U.S. 477 (1981) |
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New York v. Quarles, 467 U.S. 649 (1984) |
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Dickerson v. United States, 530 U.S. 428 (2000) |
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Berghuis v. Thompkins, 560 U.S. 370 (2010) |
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