Miranda v. Arizona

In Miranda v. Arizona, 384 U.S. 436 (1966), the United States Supreme Court held that when an individual is taken into custody or otherwise deprived of his freedom in any significant way and is subjected to questioning, he must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him. Id. at 478-479. Unless such warnings are demonstrated by the prosecution at trial, no evidence obtained as a result of the interrogation can be used against the defendant. Id. A custodial interrogation is defined as "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." Id. at 444. In Miranda v. Arizona, the United States Supreme Court held that an individual must be advised of his or her constitutional rights when law enforcement officers initiate questioning after that person has been taken into custody or otherwise deprived of his or her freedom in any significant way. Any statement given under custodial police interrogation, without the Miranda warnings first being given, may later be excluded from use by the State in any resulting criminal prosecution. Id. The Court concluded that "without proper safeguards the process of in-custody interrogation of persons suspected or accused of crime contains inherently compelling pressures which work to undermine the individual's will to resist and to compel him to speak where he would not otherwise do so freely." Id. at 467, 86 S. Ct. at 1624. Accordingly, the Court formulated the now-familiar "procedural safeguards effective to secure the privilege against self-incrimination." Id. at 444, 86 S. Ct. at 1612. Consistent with this purpose, a suspect may waive his Fifth Amendment privilege, "provided the waiver is made voluntarily, knowingly and intelligently." Id. The United States Supreme Court held that: "the prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way." ( Miranda v. Arizona, supra, 384 U.S. at p. 444.) In Miranda v. Arizona, the Supreme Court announced a set of rules meant to protect criminal suspects' rights under the fifth amendment to the United States Constitution, which provides that no person "shall be compelled in any criminal case to be a witness against himself." U.S. Const., amend. V; Miranda, 384 U.S. 436. Under Miranda, the prosecution may not use statements stemming from custodial interrogation of a suspect unless the suspect was first informed of, among other things, his rights to remain silent and speak with an attorney, and, if the suspect indicates that he does not wish to be interrogated, the police may not question him. Miranda, 384 U.S. at 444-45. In Miranda v. Arizona, the Court held that police officers must inform a suspect of enumerated constitutional rights prior to conducting a "custodial interrogation." 384 U.S. at 444. It explained, however, that its decision was "not intended to hamper the traditional function of police officers in investigating crime." Id. at 477. Consequently, the Court held as follows: When an individual is in custody on probable cause, the police may, of course, seek out evidence in the field to be used at trial against him. Such investigation may include inquiry of persons not under restraint. General on-the-scene questioning as to facts surrounding a crime or other general questioning of citizens in the fact-finding process is not affected by our holding. It is an act of responsible citizenship for individuals to give whatever information they may have to aid in law enforcement. In such situations the compelling atmosphere inherent in the process of in-custody interrogation is not necessarily present. Id. at 477-78. The United States Supreme Court held that prior to any custodial interrogation, police officers must advise a criminal suspect of his right to remain silent, to have an attorney present, and to have an appointed attorney if the suspect is indigent, and he must be warned that any statement he does make may be used against him. (Id. at p. 444.) A defendant's statements obtained in noncompliance with this rule cannot be introduced into evidence to establish his guilt. (Ibid.) However, "the defendant may waive effectuation of his Miranda rights, provided the waiver is made voluntarily, knowingly and intelligently." (Ibid.)