Pennsylvania v. Muniz

In Pennsylvania v. Muniz, 496 U.S. 582 (1990), the defendant had been asked seven questions (his name, address, height, weight, eye color, date of birth, and current age) routinely asked when a booking center received persons suspected of driving while intoxicated. (Id. at pp. 585-586.) Those questions appeared "reasonably related to the police's administrative concerns" since the state court had found the information had been requested for only record keeping purposes and the Supreme Court concluded that the questions fell outside the protections of Miranda. (Id. at pp. 601-602.) Questions that are designed to elicit incriminatory admissions, however, cannot be asked during booking unless preceded by a Miranda warning and waiver of rights. (Id. at p. 602, fn. 14.) The United States Supreme Court explained that, for purposes of the Miranda rule, the definition of "interrogation" includes more than actual questioning: "In Miranda, the Court referred to 'interrogation' as actual 'questioning initiated by law enforcement officers.' We have since clarified that definition, finding that the 'goals of the Miranda safeguards could be effectuated if those safeguards extended not only to express questioning, but also to "its functional equivalent." ' The four-justice plurality opinion in Pennsylvania v. Muniz, recognized "a 'routine booking question' exception which exempts from Miranda's coverage questions to secure the '"biographical data necessary to complete booking or pretrial services."'" ( Id. at p. 601, plur. opn. of Brennan, J.) The justices also noted an exception to the exception: "'Recognizing a "booking exception" to Miranda does not mean, of course, that any question asked during the booking process falls within that exception. Without obtaining a waiver of the suspect's Miranda rights, the police may not ask questions, even during booking, that are designed to elicit incriminatory admissions.'" ( Id. at p. 602, fn. 14.) In Muniz, the defendant sought to exclude his answers to a police officer's questions posed during booking, prior to any Miranda advisements, "regarding Muniz's name, address, height, weight, eye color, date of birth, and current age . . . ." ( Pennsylvania v. Muniz, supra, 496 U.S. at p. 601, plur. opn. of Brennan, J.) The court held the defendant's answers to these questions were admissible. The plurality opinion stated: "The state court found that the first seven questions were 'requested for record-keeping purposes only,' , and therefore the questions appear reasonably related to the police's administrative concerns. In this context, therefore, the first seven questions asked at the booking center fall outside the protections of Miranda and the answers thereto need not be suppressed." ( Id. at pp. 601-602.) A three-justice opinion concurred in this result, but under different reasoning: ". . . Muniz's responses to the first seven 'booking' questions were not testimonial and do not warrant application of the Fifth Amendment privilege against self-incrimination. Thus, it is unnecessary to determine whether the questions fall within the 'routine booking question' exception to Miranda . . . ." ( Pennsylvania v. Muniz, supra, 496 U.S. at p. 608, conc. and dis. opn. of Rehnquist, C.J.)