Miranda Rights Supreme Court Cases
The Fifth Amendment to the U.S. Constitution protects people suspected of crimes from self-incrimination. In Miranda v. Arizona, the Supreme Court applied this principle to the context of police questioning. Miranda stands for the general rule that the prosecution cannot use statements against a defendant if they were obtained through police questioning while a person was in custody or deprived of their freedom of action, unless certain procedural safeguards are applied. As a result, law enforcement provides “Miranda warnings” to people taken into custody:
- They have a right to remain silent
- Anything that they say will be used against them in court
- They have a right to consult with a lawyer and have a lawyer with them during interrogation
- If they cannot afford a lawyer, a lawyer will be appointed to represent them
The Court ruled that police questioning must cease if a person in custody indicates that they wish to remain silent. Questioning must cease until an attorney is present if a person in custody indicates that they want an attorney. To introduce statements that were obtained from questioning without the presence of an attorney, the prosecution must show that the defendant knowingly and intelligently waived their right to counsel.
Cases that have followed Miranda have addressed issues such as when a suspect has waived or invoked their rights, as well as whether questioning occurred in a sufficiently “custodial” setting to require the warnings. The Supreme Court has scaled back some of its protections over time, but the core doctrine persists.
Below is a selection of Supreme Court cases involving Miranda rights, arranged from newest to oldest.
A violation of the Miranda rules does not provide a basis for a Section 1983 claim against a police officer who improperly obtained a statement.
Howes v. Fields (2012)
Imprisonment alone is not enough to create a custodial situation within the meaning of Miranda.
J.D.B. v. North Carolina (2011)
The age of a child is relevant to the determination of whether they are in police custody for Miranda purposes.
Berghuis v. Thompkins (2010)
A suspect’s silence during interrogation did not invoke their right to remain silent. The Miranda right to counsel must be invoked unambiguously. If a suspect makes an ambiguous or equivocal statement, or no statement, the police are not required to end the interrogation or ask questions to clarify the suspect’s intent.
Maryland v. Shatzer (2010)
When a suspect experienced a break in Miranda custody lasting more than two weeks between the first and second attempts at interrogation, Edwards did not mandate the suppression of their statements.
Florida v. Powell (2010)
While the warnings prescribed by Miranda are invariable, the Supreme Court has not dictated the words in which the essential information must be conveyed. In determining whether police warnings are satisfactory, a reviewing court must determine whether the warnings reasonably convey to a suspect their rights as required by Miranda.
U.S. v. Patane (2004)
A failure to give Miranda warnings to a suspect does not require the suppression of the physical fruits of their unwarned but voluntary statements.
Missouri v. Seibert (2004)
A police officer must not make a conscious decision to withhold Miranda warnings, question first, then give the warnings, and then repeat the question until they get the answer previously given.
Dickerson v. U.S. (2000)
Since Miranda is a constitutional decision of the Supreme Court, it may not be in effect overruled by an Act of Congress.
Davis v. U.S. (1994)
After a knowing and voluntary waiver of Miranda rights, law enforcement officers may continue questioning until and unless a suspect clearly requests an attorney.
Stansbury v. California (1994)
An officer’s subjective and undisclosed view concerning whether a person being interrogated is a suspect is irrelevant to the assessment of whether the person is in custody for Miranda purposes.
Withrow v. Williams (1993)
The restriction in Stone v. Powell on the exercise of federal habeas jurisdiction does not extend to a state prisoner’s claim that their conviction rests on statements obtained in violation of the Miranda safeguards.
McNeil v. Wisconsin (1991)
An invocation of the Sixth Amendment right to counsel during a judicial proceeding does not constitute an invocation of the right to counsel derived by Miranda v. Arizona from the Fifth Amendment guarantee against compelled self-incrimination.
Minnick v. Mississippi (1990)
When counsel is requested, interrogation must cease, and officials may not reinitiate interrogation without counsel present, regardless of whether the accused has consulted with their attorney.
Pennsylvania v. Muniz (1990)
The privilege against self-incrimination protects an accused from being compelled to provide the state with evidence of a testimonial or communicative nature, but not from being compelled by the state to produce real or physical evidence. To be testimonial, the communication must explicitly or implicitly relate a factual assertion or disclose information.
Illinois v. Perkins (1990)
Miranda warnings are not required when the suspect is unaware that they are speaking to a law enforcement officer and gives a voluntary statement.
Patterson v. Illinois (1988)
An accused who is admonished with the Miranda warnings has been sufficiently apprised of the nature of their Sixth Amendment rights and the consequences of abandoning those rights so that their waiver on this basis will be considered knowing and intelligent.
Arizona v. Roberson (1988)
The Edwards rule applies to bar police-initiated interrogation following a suspect’s request for counsel in the context of a separate investigation.
Arizona v. Mauro (1987)
The purpose of Miranda and Innis is to prevent the government from using the coercive nature of confinement to extract confessions that would not be given in an unrestrained environment. This purpose is not implicated when a suspect is not subjected to compelling influences, psychological ploys, or direct questioning.
Connecticut v. Barrett (1987)
Although the Miranda rules were designed to protect defendants from being compelled by the government to make statements, they also give defendants the right to choose between speech and silence.
Colorado v. Connelly (1986)
The sole concern of the Fifth Amendment, on which Miranda was based, is governmental coercion.
Moran v. Burbine (1986)
Miranda should not be extended to require the reversal of a conviction if the police are less than forthright in their dealings with an attorney or if they fail to tell a suspect of an attorney’s unilateral efforts to contact them.
Oregon v. Elstad (1985)
The Fifth Amendment does not require the suppression of a confession, made after proper Miranda warnings and a valid waiver of rights, solely because the police had obtained an earlier voluntary but unwarned admission from the suspect.
Berkemer v. McCarty (1984)
The roadside questioning of a motorist detained pursuant to a routine traffic stop does not constitute “custodial interrogation” for the purposes of the Miranda rule.
New York v. Quarles (1984)
The doctrinal underpinnings of Miranda do not require that it be applied in all its rigor to a situation in which police officers ask questions reasonably prompted by a concern for the public safety.
Oregon v. Bradshaw (1983)
A suspect initiates further conversation within the meaning of Edwards when their statement evinces a willingness and a desire for a generalized discussion about the investigation, rather than pursuing a necessary inquiry arising out of the incidents of the custodial relationship.
Edwards v. Arizona (1981)
When an accused has invoked their right to have counsel present during custodial interrogation, a valid waiver of that right cannot be established by showing only that they responded to police-initiated interrogation after again being advised of their rights. When an accused has expressed their desire to deal with the police only through counsel, they are not subject to further interrogation until counsel has been made available to them, unless they have initiated further communication, exchanges, or conversations with the police.
Rhode Island v. Innis (1980)
The Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent. The term “interrogation” under Miranda refers not only to express questioning but also to any words or actions on the part of the police that they should know are reasonably likely to elicit an incriminating response from the suspect.
Fare v. Michael C. (1979)
A juvenile defendant’s request for their probation officer was not a per se invocation of their Fifth Amendment rights under Miranda.
Doyle v. Ohio (1976)
A prosecutor may not seek to impeach a defendant’s exculpatory story, told for the first time at trial, by cross-examining the defendant about their failure to have told the story after receiving Miranda warnings at the time of their arrest.
Beckwith v. U.S. (1976)
Statements made by a taxpayer to Internal Revenue agents during the course of a non-custodial interview in a criminal tax investigation were admissible against them in an ensuing criminal tax fraud prosecution, even though they were not given Miranda warnings.
Michigan v. Moseley (1975)
The admissibility of statements obtained after the person in custody has decided to remain silent depends under Miranda on whether their right to cut off questioning was scrupulously honored.
Brown v. Illinois (1975)
State courts were in error in assuming that the Miranda warnings, by themselves, under Wong Sun v. U.S. always purge the taint of an illegal arrest.
Miranda v. Arizona (1966)
The prosecution may not use statements stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. Custodial interrogation means questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of their freedom of action in any significant way. Prior to any questioning, the person must be warned that they have a right to remain silent, that any statement that they make may be used as evidence against them, and that they have a right to the presence of an attorney, either retained or appointed.