Limitations on Miranda & Custody / Interrogation Flashcards
Harris v. New York
In a 5-to-4 decision, the Court held that the Miranda decision did not mandate that evidence inadmissible against an accused in the prosecution’s case must be barred for all purposes from the trial. The Court reasoned that the shield provided by Miranda could not be “perverted into a license to use perjury by way of a defense, free from the risk of confrontation with prior inconsistent utterances.” The Court found that the speculative possibility that police misconduct could be encouraged was outweighed by the value of admitting the statement into the impeachment process.
Doyle v. Ohio
Held: The use for impeachment purposes of petitioners’ silence, at the time of arrest and after they received Miranda warnings, violated the Due Process Clause of the Fourteenth Amendment. Post-arrest silence following such warnings is insolubly ambiguous; moreover, it would be fundamentally unfair to allow an arrestee’s silence to be used to impeach an explanation subsequently given at trial after he had been impliedly assured, by the Miranda warnings, that silence would carry no penalty.
Oregon v. Hass
When a suspect in police custody has been given and accepts the full warnings prescribed by Miranda v. Arizona, and later states that he would like to telephone a lawyer, but is told he cannot do so until reaching the station, and he then provides inculpatory information, such information is admissible in evidence at the suspect’s trial solely for impeachment purposes after he has taken the stand and testified to the contrary knowing such information had been ruled inadmissible for the prosecution’s case in chief.
Fletcher v. Weir
Held: Respondent was not denied due process of law under the Fourteenth Amendment by the prosecutor’s use, at respondent’s state court trial which resulted in a conviction for first-degree manslaughter, of his post-arrest silence for impeachment purposes – the record not indicating that respondent had been given the warnings required by Miranda v. Arizona, 384 U. S. 436, during the period in which he remained silent immediately after his arrest.
Subsequent Confessions: Oregon v. Elstad
Held: The Self-Incrimination Clause of 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.
Missouri v. Seibert - Attenuation
The relevant inquiry is whether Miranda warnings delivered midstream in a two-stage interrogation are effective, which requires analysis of:
(1) the thoroughness and detail of the questions and answers in the first round of interrogation,
(2) how much the content of the suspect’s two statements overlap,
(3) the timing and setting of each round of interrogation,
(4) whether the officers were the same in both rounds, and
(5) to what extent the second interrogator treated the second round as a continuation of the first.
US v. Patane-Physical Evidence Derived from Miranda-Defective Confessions
three justices wrote that the Miranda warnings were merely intended to prevent violations of the Constitution, and that because Patane’s un-Mirandized testimony was not admitted at trial the Constitution (specifically the Fifth Amendment’s protection against self-incrimination) had not been violated.
Physical evidence obtained from un-Mirandized statements, as long as those statements were not forced by police, were constitutionally admissible.
New York v. Quarles - Public Safety Exception
Held: The Court of Appeals erred in affirming the exclusion of respondent’s initial statement and the gun because of Officer Kraft’s failure to read respondent his Miranda rights before attempting to locate the weapon. Accordingly, it also erred in affirming the exclusion of respondent’s subsequent statements as illegal fruits of the Miranda violation. This case presents a situation where concern for public safety must be paramount to adherence to the literal language of the prophylactic rules enunciated in Miranda.
Rhode Island v. Innis—What is Interrogation
Held: Respondent was not “interrogated” in violation of his right under Miranda to remain silent until he had consulted with a lawyer
(a) The Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent.
(b) Here, there was no express questioning of the respondent; the conversation between the two officers was, at least in form, nothing more than a dialogue between them to which no response from the respondent was invited.
United States v. Brown
(1) whether the suspect was informed at the time of questioning that the questioning was voluntary, that the suspect was free to leave or request the officers to do so, or that the suspect was not considered under arrest; (2) whether the suspect possessed unrestrained freedom of movement during questioning;
(3) whether the suspect initiated contact with authorities or voluntarily acquiesced to official request to respond to questions;
(4) whether strong arm tactics or deceptive stratagems were employed during questioning;
(5) whether the atmosphere of the questioning was police dominated; and
(6) whether the suspect was placed under arrest at the termination of the questioning.
