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The Importance of Miranda v. Arizona
People in the United States are familiar with the following scenario: someone is in police custody, being interrogated for a crime. The police officer approaching the person detained recites: “You have the right to remain silent. Anything you say can and will be used against you in a court of law. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you. Do you understand the rights I have just read to you? With these rights in mind, do you wish to speak to me?” These rights are colloquially referred to as Miranda rights because they originated with Miranda v. Arizona (1966). In the respective case, police arrested and interrogated Ernesto Miranda in connection with a kidnapping and rape, leading to Miranda’s written confession. The confession was admitted as evidence at trial, however Miranda was never read his Fifth and Sixth Amendment rights prior to confessing. After Miranda was found guilty, he appealed to the Supreme Court of Arizona, which held that Miranda’s constitutional rights were not violated. Miranda further appealed to the U.S. Supreme Court, which overturned the Arizona judgment, determining that law enforcement was required to inform Miranda of his rights to remain silent and to consult with an attorney while undergoing police interrogation.
Despite this landmark ruling, Miranda rights have been continuously weakened and frequently disregarded. Law enforcement officers often fail to inform people held in custody of their Miranda rights, causing those accused to unknowingly make incriminating statements or confessional comments which are admitted as evidence at trial unless specifically disputed by detainees’ counsel. This recurring tendency can be attributed to a conglomerate of Supreme Court rulings; however, this analysis focuses on three subsequent cases of key importance: Duckworth v. Eagan (1989), Missouri v. Seibert (2003), and Bobby v. Dixon (2011).
Cases Weakening Miranda Rights
Access to an attorney – during an interrogation and throughout a trial – is embedded in the Fifth Amendment. However, it was not exercised in Duckworth v. Eagan. Eagan, who was accused of stabbing a woman, was not made aware of his right to an attorney as required by Miranda v. Arizona. After he was taken in for questioning, law enforcement partially informed him of his rights, only conveying to him that a lawyer would be made available “if and when you go to court.” That day, he signed a waiver with this phrasing, without further implicating himself during questioning. On the following day, Eagan signed a waiver with the proper Miranda warning. Police continued questioning him until he was prompted to confess to the stabbing of the woman and provided evidence of the crime.
Eagan’s incriminating statements were admitted as evidence at trial and he was convicted. The Indiana Supreme Court upheld the conviction. Eagan then brought his case to the District Court, claiming that his statements were inadmissible due to the language in his first waiver not complying with Miranda v. Arizona. While the District Court denied Eagan’s petition, the Appellate Court reversed this ruling, arguing Eagan’s original Miranda warning was inadequate. The U.S. Supreme Court disagreed, however, determining that the “if and when you go to court” language did not render the defendant’s Miranda warning inadequate. In fact, the U.S. Supreme Court reasoned that law enforcement officers are not required to provide suspects with the exact language outlined in Miranda. Eagan was not given the proper opportunity to consult with counsel before confessing to attempted murder due to law enforcement’s failure to inform him of this right, and the decision in Duckworth v. Eagan opened the door for further violations of constitutional rights.
In the case of Missouri v. Seibert, law enforcement intentionally withheld the Miranda warning from Patrice Seibert, leading her to confess to a murder. Seibert was questioned in connection to a fire and the subsequent death of a man named Donald Rector, which both occurred at her mobile home. Police arrested Seibert, did not provide her with her Miranda rights, and questioned her for approximately 30 minutes. Seibert confessed to intentionally leaving Rector to die in the fire, at which point police halted questioning. Police returned, read Seibert the Miranda warning, and prompted Seibert to sign an acknowledgement waiver and repeat her confession. Seibert’s original confession was deemed inadmissible at trial, however, her Mirandized confession was admitted and she was convicted of second degree murder.
The Missouri Court of Appeals upheld the trial court’s ruling. However, the Missouri Supreme Court reversed the ruling, claiming that the second statement was a direct product of the first, invalid statement, deeming it invalid. Despite law enforcement’s intentional failure to provide Seibert with her Miranda rights, the U.S. Supreme Court overturned the Missouri Supreme Court’s ruling. This ruling made Seibert’s second confession admissible, despite police only obtaining it after she confessed to the crime without the proper warnings. In his concurring opinion, Justice Anthony Kennedy argued that the two-step questioning technique administered by the police was a deliberate violation of Miranda v. Arizona. Despite this specification, Kennedy still sided with the majority ruling.
Similarly, in the case of Bobby v. Dixon, law enforcement intentionally failed to read Archie Dixon his Miranda rights. Archie Dixon and Tim Hoffner murdered Chris Hammer, stole his car, and utilized Hammer’s birth certificate and social security card to fraudulently sell Hammer’s vehicle. Throughout the investigation of Hammer’s disappearance, Dixon had three encounters with law enforcement, the first of which was entirely by chance. Dixon arrived at the police station to retrieve his own car. Upon arrival, law enforcement read him his Miranda rights and asked to discuss Hammer’s disappearance. He declined to do so. Police later arrested Dixon for forgery and began interrogating him without reading him his Miranda rights. Police worried that he would again refuse to answer any questions if they did so. Moreover, police ignored his request to speak with counsel and continued questioning. Dixon admitted to forging Hammer’s signature; however, he claimed that he had done so with Hammer’s permission and knew nothing of Hammer’s whereabouts. He was charged with forgery and brought to a correctional facility. Shortly thereafter, Hoffner led police to Hammer’s grave and police again questioned Dixon in two sessions. Prior to the second session, police intentionally withheld Dixon’s Miranda warning due to fear that he would request to speak with counsel. During the second session, and after police read him his Miranda rights, he confessed.
Dixon’s confessions, both to forgery and murder, were deemed inadmissible at trial. The Ohio Court of Appeals allowed for Dixon’s murder confession to be admitted, maintaining however that his forgery confession was inadmissible, and convicted him of murder, kidnapping, robbery, and forgery. The Ohio Supreme Court affirmed the Appellate Court’s ruling. The Sixth Circuit court claimed that Dixon’s Fifth and Sixth Amendment rights were violated and that none of Dixon’s confessions were voluntary or admissible. The U.S. Supreme Court overturned the Sixth Circuit court’s ruling, determining that police did not violate Dixon’s Constitutional rights and all statements were made voluntarily and with proper warning. Such a decision has contributed again to weakening Miranda rights.
A Case Affirming Miranda Rights
Despite cases such as Duckworth v. Eagan, Missouri v. Seibert, and Bobby v. Dixon having weakened Miranda rights, the ruling in the case of Arizona v. Roberson (1988) has broadened Miranda. After his arrest at the scene of a burglary and the subsequent reading of his Miranda rights, Ronald Roberson declined to answer any questions prior to speaking with counsel. A few days later, a different law enforcement officer questioned Roberson in connection with a separate robbery and Roberson implicated himself. This officer, however, was unaware that Roberson had previously invoked his Fifth Amendment right to speak with a lawyer.
Roberson’s statement was suppressed in trial court. The Arizona Court of Appeals affirmed this suppression, while the Arizona Supreme Court declined to review the case. In a six to two decision, the U.S. Supreme Court ruled that the officer’s questioning violated the Fifth Amendment and Roberson’s statement was deemed inadmissible in court. Additionally, the Court asserted that for questioning to continue following the invocation of the Fifth Amendment, the suspect must initiate the conversation rather than the police.
The Present and Future of Miranda Rights and Constitutional Rights
As evidenced by the ruling of Vega v. Tekoh (2022), Miranda rights continue to lack sufficient practical application. In this case, Terence Tekoh, a hospital patient transporter, was accused of sexual assault by a patient. The police did not advise Tekoh on his Miranda rights prior to questioning him. Tekoh was charged in California state court, but a jury found him not guilty. Tekoh sued the police officer claiming his Fifth Amendment rights pertaining to self-incrimination were violated as he was not advised on his Miranda rights. The District Court denied his claim, whereas the Appellate Court subsequently reversed the verdict. The U.S. Supreme Court ruled that a Miranda violation is not necessarily a Fifth Amendment violation. Additionally, the majority claimed that allowing people to sue police for noncompliance with Miranda would impose an unwelcome burden on the judicial system.
Despite the landmark decision Miranda v. Arizona, the U.S. Supreme Court and lower courts often rule in contradiction to the Miranda precedent, which is worrisome. The rights granted in the Fifth and Sixth Amendments are crucial to democracy and the liberties of people residing in the United States, and must be treated as such.
