Dickerson v. United States

In Dickerson v. United States, 530 U.S. 428, 120 S. Ct. 2326, 147 L. Ed. 2d 405 (2000), the United States Supreme Court held that Miranda's familiar protections are constitutional in nature and thus could not be superseded by a mere act of Congress. The Chief Justice's majority opinion offered several reasons for the Court's ultimate conclusion. First, the Court applied the rule to the states, something it cannot do absent a constitutional violation. Second, the Court stated that its conclusion about Miranda's constitutional status was buttressed by its prior recognition that Miranda challenges could be mounted in habeas corpus proceedings. Third, specific language in Miranda itself suggests that "the majority thought it was announcing a constitutional rule." Fourth, the Court in Miranda invited legislative action to "protect the constitutional right against coerced self-incrimination" where such action was at least as effective as the Miranda warnings themselves. Fifth, subsequent cases have "referred to Miranda's constitutional underpinnings." Finally, stare decisis weighed in favor of preserving Miranda's protections because they have "become embedded in routine police practice to the point where the warnings have become part of our national culture." Id. at 2336. In Dickerson, Chief Justice Rehnquist, speaking for the Court, rejected the rule that a defendant's custodial statement should be admissible if, under the totality of circumstances, the court finds that the statement was given voluntarily and without mental or physical coercion, regardless of whether the defendant has been given Miranda warnings and invoked his right to consult an attorney. Id. at 2336.