How Does the United States Supreme Court Define the Term 'Interrogation' ?
In Rhode Island v. Innis, 446 U.S. 291, 64 L. Ed. 2d 297, 100 S. Ct. 1682 (1980), the United States Supreme Court defined the term "interrogation."
In Innis, the respondent was arrested and advised of his Miranda rights.
The respondent informed the police that he wished to speak with an attorney, and the police placed the respondent in a police vehicle in order to transport the respondent to the police station.
While in route to the police station, two of the police officers in the police vehicle with the respondent had a conversation in which one of the police officers voiced his concern that it would be bad if one of the disabled children from a local school found the missing weapon and was injured or killed.
The respondent interrupted the officers' conversation and asked the police officers to turn the vehicle around so he could show them where the weapon was located.
The issue before the Supreme Court in Innis was "whether the respondent was 'interrogated' by the police officers in violation of the respondent's undisputed right under Miranda to remain silent until he had consulted with a lawyer." Innis, 446 U.S. at 298, 64 L. Ed. 2d at 306,100 S. Ct. at 1688.
The Innis Court concluded "that the Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent." Innis, 446 U.S. at 300-01, 64 L. Ed. 2d at 307-08, 100 S. Ct. at 1689.
The Innis Court explained that the "functional equivalent" of express questioning was "any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect." Innis, 446 U.S. at 301, 64 L. Ed. 2d at 308, 100 S. Ct. at 1689-90.
Specifically, the Court found that it could not be said that the police officers should have known that their conversation was reasonably likely to elicit an incriminating response from the respondent. Innis, 446 U.S. at 302, 64 L. Ed. 2d at 309, 100 S. Ct. at 1690.
The Innis Court held that, in the facts before it, the respondent was not interrogated within the meaning of Miranda. Innis, 446 U.S. at 302, 64 L. Ed. 2d at 308, 100 S. Ct. at 1690.