Miranda V. Arizona
In Miranda v. Arizona, 384 U.S. 436 (1966), the Supreme Court articulated the procedural requirements for the United States Constitution, which safeguards of the Fifth Amendment right against self-incrimination. This decision prohibited the use at trial of inculpatory and exculpatory statements made by an individual in police custody in the absence of demonstration that police followed procedural safeguards. The decision further indicated that the administration of warning regarding the rights of the individual in custody were not merely procedural rules, but derived from constitutional rights. In Harris v. New York, 401 U.S. 222 (1971), the Supreme Court began to carve exceptions to the rule stated in Miranda. As the number of exceptions to the rule increased in subsequent decisions, Congress attempted to substitute a test based on its authority to establish federal rules of procedure with respect to determining whether an admission is voluntary. The Supreme Court ruled the legislation unconstitutional in Dickerson v. United States, 530 U.S. 428 (2000), raising the concern that the Supreme Court was usurping Congressional authority by requiring that any statutory rule regarding custodial admissions conform closely to the Miranda warnings.
The Supreme Court granted certiorari to petitioner in Miranda based on the jurisdiction of the federal courts to adjudicate constitutional issues and following hearings in the Arizona State Supreme Court and federal district and appellate courts. The issues before the court was the whether the Fifth Amendment protection against coerced self-incrimination required that defendants in custody be informed of the constitutional right to remain silent and whether the right to counsel was implied by the Fifth Amendment protection against self incrimination. In the facts of this case, petitioner made a written confession to a crime while in police custody. At no time was petitioner advised of his constitutional right to avoid self-incrimination, although the written confession contained a clause indicating that it was made with his full knowledge. In addition, petitioner was not informed that his statements could be used against him at trial or that legal counsel could be provided. The argument of petitioner was that the custody interrogation was coercive and that he was not aware of his constitutional right to avoid self-incrimination or to consult with an attorney. Petitioner further argued that the confession should be suppressed based on the exclusionary rule and that he should be granted a new trial. The argument of respondent was that the confession was voluntarily made without coercion, and was therefore constitutional.