Miranda v. Arizona

By: Ben Beauchamp

What Happened?

Ernesto Miranda was arrested in Phoenix due to circumstantial evidence that he had been involved in a kidnapping and rape. He confessed to the charges following a lengthy interrogation and signed a statement that said the confession was made knowingly and voluntarily. Miranda never was told of his right to remain silent, of his right to have a lawyer, or of the fact that any of his statements during the interrogation could be used against him in court. He objected to the introduction of the written copy of his confession into evidence at trial, stating that his ignorance of his rights made the confession involuntary. At trial, when prosecutors offered Miranda's written confession as evidence, his court appointed lawyer, Alvin Moore objected that because of these facts, the confession was not truly voluntary and should be excluded. Moore's objection was overruled and based on this confession and other evidence, Miranda was convicted of rape and kidnapping. He was sentenced to 20-30 years of imprisonment on each charge, with sentences to run concurrently. Moore filed Miranda's appeal to the Arizona Supreme Court, claiming that Miranda's confession was not fully voluntary and should not have been admitted into the court proceedings. The Arizona Supreme Court affirmed the trial court's decision to admit the confession in State v. Miranda, 401 P.2d 721 (Ariz. 1965). In affirmation, the Arizona Supreme Court emphasized heavily the fact that Miranda did not specifically request an attorney.

Who is Ernesto Miranda?

Ernesto was a laborer whose conviction on kidnapping, rape, and armed robbery charges based on his confession under police interrogation was set aside in the landmark U.S. Supreme Court case (Miranda v. Arizona), which ruled that criminal suspects must be informed of their right against self-incrimination and their right to consult with an attorney before being questioned by police. This warning is known as a Miranda Warning. After the Supreme Court decision set aside Miranda's initial conviction, the state of Arizona retried him. At the second trial, with his confession excluded from evidence, he was again convicted.

BornMarch 9, 1941
Mesa, Arizona

DiedJanuary 31, 1976 (aged 34)
Phoenix, Arizona

Cause of death

Stabbing

Resting place

City of Mesa Cemetery

OccupationLaborer

Known forMiranda Rights

Criminal charge

Kidnapping and Rape

Criminal statusConvicted

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How did the Miranda v. Arizona case become controversial?

It was the most television-friendly of the Supreme Court cases. It also dealt with the 5th amendment which is in the constitution. It was the most television-friendly of the Supreme Court cases. It also dealt with the 5th amendment which is in the constitution. This decision made by the Supreme Court was very controversial at the time of its ruling because many people believed that the ruling would allow more criminals to go free because of courtroom technicalities. Many other important cases followed the Miranda decision, which still remains a controversial topic today. Several cases followed Miranda versus Arizona in which defendants made incriminating statements to police without being told their Miranda rights.

Is Miranda Applicable?

Miranda does NOT apply unless a person is in custody and subjected to interrogation by a law enforcement officer.

1. Custody

Definitions:

  • Custody requires a significant deprivation of liberty.
  • A person is in custody only if they are subjected to either formal arrest or its functional equivalent.
    • Formal arrest—occurs when a person is explicitly told they are being placed under arrest or is booked at the station-house.
    • Functional equivalent—occurs when a suspect is “deprived of his freedom of action in any significant way.”

Consider a reasonable person under the same conditions of the suspect:

  • Would a reasonable person under the same circumstances believe they were free to leave? (In other words: what would an average or typical member of the community think under the same circumstances?)
  • The Court is not trying to figure out what this particular suspect thought.

2. Interrogation by a law enforcement officer

Even if the person is in custody, Miranda only applies if the suspect was interrogated by known law enforcement officers.

Definitions:

  • Interrogation—includes any direct questioning by officers about a crime under investigation and more subtle statements or conduct that are the functional equivalent of direct questioning
  • The functional equivalent of direct questioning is any speech or actions by an officer that they should have known were reasonably likely to elicit an incriminating response.

Determining the functional equivalent:

  • Reasonably likely:
    • Courts will deem it "interrogation" only if officers knew or should have known an incriminating response was reasonably likely. (Note: What the officer should have known is judged from the perspective of a reasonable officer in the same situation.)
  • Officer's intent:
    • Courts will probably consider it to be interrogation if the officer actually intended that their words or conduct would elicit an incriminating response.
  • Officer's knowledge of the suspect:
    • Courts will usually treat it as interrogation if an officer was aware of —and exploited—a suspect's unusual weakness or fear.

Spontaneous, volunteered statements:

Spontaneous statements volunteered by the suspect without questioning are NOT considered the product of interrogation even if the suspect was in custody at the time.

3. The Public Safety Exception to Miranda

The U.S. Supreme Court has ruled that Miranda warnings are unnecessary prior to questioning that is “reasonably prompted by a concern for the public safety”

  • Consider whether a reasonable officer in the same position would conclude that there is a significant threat to the public safety
  • Example: interrogation that occurs as police try to locate a bomb they believe is set to go off

Criticisms?

This is Historical because it had to deal with a previous event in history. It's not in the present. This is also cultural criticism because it deals with the society as a whole not an individual.

Biases?

In an article I read on PBS's website I found the bias of Alex McBride in which he said," Ernesto Miranda, whose wrongful conviction led to the landmark case Miranda v. Arizona, in which the Court held that detained criminal suspects must be informed of their rights prior to police questioning."

How the Media portrayed the event?

The media thought his conviction was faulty, and he deserved a new trial. Although in some people's eyes he had broken the law. Ernesto Miranda was no stranger to police procedures.
He negotiated with police officers with intelligence and understanding.
He signed the confession willingly. The prosecution was proper, his conviction based on Arizona law, and his imprisonment was justified.

Work Cited!

"Earl Warren." Wikipedia. Wikimedia Foundation. Web. 30 Apr. 2015.


"Facts and Case Summary." USCOURTSGOV RSS. Web. 30 Apr. 2015.


"Miranda v. Arizona." Wikipedia. Wikimedia Foundation. Web. 30 Apr. 2015.


"MIRANDA v. ARIZONA." Miranda v. Arizona. Web. 30 Apr. 2015.