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Analyzing Appellate Court CaseResearch Paper

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¶ … Miranda v. Arizona appellate court case.

Miranda v. Arizona Background

In this paper, I choose to explore the popular Miranda v. Arizona case. With the basis for its decisions lying in the 1961 Mapp v Ohio case, 1963 Gideon v Wainwright case, and the 1964 Escobedo v. Illinois case, the U.S. Supreme Court under Warren handed down its bases for the standard of "fundamentals of fairness." At federal as well as state levels, the Supreme Court sent an explicit signal to criminal justice and law enforcement officials. Verdicts that did not conform to this "fairness" standard were likely to be overturned. Maintenance of the due process guaranteed for accused parties was essential (Miranda v. Arizona (1966)). Together with Miranda, several other similar cases were heard by the Supreme Court, but as the case finds its name at the forefront of the docket, the collective judgment of the Court is popular by the name of Miranda. The Court's decision on this case distilled the numerous standards of "fundamental fairness" into a single concise statement of accused parties' rights to due process. The warning provided by Miranda has developed into a familiar citizens' rights statement, courtesy of TV police shows. In March of 1963, a sexual assault and kidnapping took place in Arizona's capital city, Phoenix. On 13th March, 23-year-old Ernesto Miranda was arrested at home, driven to a police station where the victim identified him, and taken in for interrogation. The culprit was not informed of his right to counsel before being questioned (Miranda v. Arizona (1966)). A couple of hours into interrogation, law enforcement investigators left the room bearing a written and signed confession by the criminal, including a typed and signed disclaimer which stated that the perpetrator was fully aware of his legal rights, understood that all statements made by him could be used against him in court, and knowingly relinquished these rights. A couple of weeks after this event, came his first hearing, at which the defendant was once again denied counsel. While he did utilize a lawyer's services at trial, the latter's objection to using the defendant's signed declaration of guilt as evidence was overruled. The defendant was found guilty of abduction and rape, receiving a prison sentence of twenty years. Still, the case was able to raise critical issues pertaining to human liberties, and this is the reason for my choice of case for this paper.

The Opinion of Case

Prosecutors may not make use of inculpatory or exculpatory statements, resulting from questioning begun by law enforcers after an individual has been apprehended or otherwise divested of freedom to act in any major way, unless they demonstrate application of procedural protections successful in securing Amendment V privileges against self-implication. The setting and conditions of modern-day incommunicado interrogations are integrally frightening, and serve to weaken privileges against self-implication. Unless satisfactory preventive steps are undertaken for dispelling the compulsion characteristic of custodial surroundings, a defendant's statements cannot truly result from his/her free choosing (Miranda v. Arizona: 384 U.S. 436 (1966): Justia U.S. Supreme Court Center). The constitutional privilege against forced self-incrimination -- an issue that has a lengthy history -- is the critical pillar of the nation's adversary system. It guarantees individuals a right of silence unless he/she elects to speak up by freely exercising his/her own will, throughout custodial interrogations, trials at court, and other authorized investigations. Without other sound measures, the procedures cited below, which safeguard the Amendment V privilege, have to be observed: before interrogation, the fact that suspects have a right to silence, and whatever they say can be used at trial against them, should be explicitly communicated to them. Further, it should be made clear to them that they enjoy a right to consultation with any lawyer; their lawyer can be present at the time of interrogation. Lastly, if the suspect is unable to afford the services of a private lawyer, he/she will be allotted a lawyer, who will represent him/her in court.

Issues Raised by Opinion

The term 'self-incrimination' implies making such a statement before a law enforcement authority, which implicates oneself in some criminal offense, leading to prosecution at present or in future. Self-implication can occur indirectly (a voluntary statement made without coercion) or directly (a self-implicating statement made in the course of interrogation). The U.S. Constitution's 5th Amendment affords citizens a right to decline answering questions or making self-implicating statements. If a suspect at trial states that he/she "pleads the Fifth," he/she invokes this privilege against self-implication (Self-Incrimination). Amendment V also affords the suspect a right to refuse to testify at trial. The prosecutor, judge, and suspect's lawyer may not coerce him/her into testifying. Additionally, if the defendant decides against bearing witness, the jury is not allowed to hold this refusal against the defendant in the course of deciding the case's verdict. If the suspect chooses to testify, the court considers his/her Amendment V rights waived, and the suspect will then have to answer every question thrown at him/her by the lawyers. Witnesses can plead this right in the witness box if the reply to any question implicates him/her. The reason for this is, unlike defendants, witnesses might be compelled or forced to testify. Amendment V is not only applicable at the time of trial. In the Miranda case, the United States Supreme Court declared that the police should inform a defendant of his/her right to silence and hiring/obtaining a lawyer prior to interrogation. These came to be known popularly as the "Miranda Rights." Against popular belief, these rights are not required to be stated before suspects after all arrests. Unless the law enforcement officer is about to interrogate the suspect, the latter need not know of the above rights. Thus, if a self-implicating statement is made of the suspect's own accord, it can be admitted at trial. Such statements made prior to capturing the individual can be utilized as evidence too.

In spite of the apparently entrenched status held by the Miranda case's warning in American pop culture and legal circles, the October 1999 Dickerson v. U.S. case proved a threat to the three-decade reign of Miranda (Focus on the Fifth: Miranda v. Arizona -- FindLaw). The defendant in this case confessed to driving a getaway automobile in a succession of bank thefts. But Dickerson's confession was suppressed by the (lower) District Court, as it found that the defendant's statement was made in law enforcement custody, as a response to interrogation, without mandatory Miranda warning.

Upon appeal, a question posed to the 4th Circuit Appellate Court was whether the post-Miranda 18 U.S.C.A. § 3501 statute the Congress enacted under its 1968 Omnibus Crime Control Act was constitutional. The statute partly declares that in criminal cases instituted by the U.S., only voluntary confessions may be admitted as evidence. If this is a constitutional statute, it returns the standard that governs confession admissibility back to pre-Miranda standards of voluntariness. The following rulings were given by the 4th Circuit (Focus on the Fifth: Miranda v. Arizona -- FindLaw):

The U.S. Congress is authorized to reverse rules of procedure and evidence formulated by the judiciary but not constitutionally-mandated. Hence, whether the Congress can enact section 3501 depends on whether or not the Supreme Court's Miranda rule is a Constitutional mandate.

In Miranda, the U.S. Supreme Court did not, at any juncture, call its warnings "constitutional rights." In fact, it acknowledged the fact that the warnings weren't Constitutional requirements, and disclaimed all intent to establish any "constitutional straightjacket" -- i.e., warnings that function in the form of "procedural safeguards." It invited the States and Congress to create their own separate safeguards to protect the privilege.

Ever since the Miranda case was decided, the U.S. Supreme Court has always called its Miranda warnings "prophylactic"; they are not, by themselves, Constitutional rights.

On the basis of the above findings, the 4th Circuit reached the conclusion that Section 3501, passed at the Supreme Court's invitation and in accordance to the Congress's unquestioned authority to institute rules of evidence and procedure in federal courts of law, is indeed legitimate (Focus on the Fifth: Miranda v. Arizona -- FindLaw). Thus, the court ruled that Section 3501, and not the Miranda rule created by the judiciary, governs confessions' admissibility in federal courts.

Expert Commentary

The Miranda warning stemmed from Chief Justice Warren's quest for democratic philosophy. The underlying logic was that intelligent, rich, and educated individuals who are detained are quite likely aware from the start of their right of silence, while unintelligent, poor, and unschooled suspect will not know of it. As a result, to be fair to all, each custodial suspect should be informed of this right. Furthermore, for ensuring that such detainees have complete knowledge of all aspects of the privilege, they must be informed of their right to a lawyer as well, who can attend to both police interrogations and court trial (Inbau and Manak, 1987). Counter to the common impression, even in legal circles, the Supreme Court's stipulated warning concerning the right of… [END OF PREVIEW]

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