Brief Summary (IRAC Pattern)
Issue: Whether the Fifth Amendment’s protection against self-incrimination extends to the police interrogation of a suspect.
Rule: The Fifth Amendment requires that law enforcement officials advise suspects of their right to remain silent and to obtain an attorney during interrogations while in custody.
Application: Ernesto Miranda was arrested and interrogated by police without being informed of his right to counsel or his right to remain silent. He confessed to the charges after a two-hour interrogation. The Supreme Court held that the statements made by Miranda during the interrogation could not be used as evidence because he had not been informed of his rights.
Conclusion: The conviction was overturned. The Supreme Court established the “Miranda rights,” requiring police to inform suspects of their rights before interrogation.
Detailed IRAC Outline
Issue
The primary issue in Miranda v. Arizona is whether the constitutional rights of Ernesto Miranda were violated when he was arrested and interrogated without being informed of his Fifth Amendment rights to remain silent and to have legal counsel.
Rule
The rule established by the Supreme Court in Miranda v. Arizona is that the Fifth Amendment’s privilege against self-incrimination requires law enforcement officials to advise a suspect interrogated in custody of their rights to remain silent, that any statement they do make may be used as evidence against them, and to have the right to the presence of an attorney, either retained or appointed.
Application
Facts:
- Ernesto Miranda was arrested for kidnapping and rape.
- He was interrogated by police officers for two hours.
- Miranda signed a confession that included a typed paragraph stating that he had made the confession voluntarily, without threats or promises of immunity, and “with full knowledge of my legal rights, understanding any statement I make may be used against me.”
- However, he was not informed of his right to counsel or his right to remain silent before the interrogation.
Lower Court Proceedings:
- The confession was admitted into evidence at trial, and Miranda was convicted.
- The Arizona Supreme Court affirmed the conviction, holding that Miranda’s constitutional rights were not violated because he did not specifically request counsel.
Supreme Court Analysis:
- The Supreme Court reviewed multiple cases where the absence of proper warnings about rights led to involuntary confessions.
- The Court determined that the interrogation environment is inherently coercive and that without proper safeguards, there is a heavy potential for compulsion of self-incrimination.
- The Court concluded that without warnings and an understanding of rights, the confession could not be considered the product of a rational intellect and a free will.
Conclusion
The Supreme Court concluded that Miranda’s confession was obtained in violation of his Fifth Amendment rights and therefore was not admissible as evidence against him in a criminal trial. His conviction was overturned. The Court established the Miranda warnings, setting forth the procedure that must be employed to protect a suspect’s Fifth Amendment rights during custodial interrogation.