Miranda Reconsidered: Supreme Court Review of Miranda Rights in United States v. Patane Missouri v. Seibert, and Fellers v. United States (CRS Report for Congress)
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| Release Date |
July 26, 2004 |
| Report Number |
RL32224 |
| Report Type |
Report |
| Authors |
Estela I. Velez Pollack, American Law Division |
| Source Agency |
Congressional Research Service |
Summary:
The United States Supreme Court created the now well-known Miranda warnings
to preserve the
right against self-incrimination provided by the Fifth Amendment of the Constitution and the right
to counsel provided by the Sixth Amendment. These warnings provide that prior to questioning,
individuals suspected of a crime must be informed of their right to remain silent, that anything they
say may be used against them in court, that they have the right to an attorney, and if they cannot
afford one, that a lawyer will be appointed to represent them. Miranda v. Arizona , 384
U.S. 425
(1966). Aside from serving to inform people of their rights, the Miranda decision is
meant to guide
the police and deter improper conduct.
This term the United States Supreme Court decided two cases that challenged
Miranda : United
States v. Patane , and Missouri v. Seibert . In Patane, the United States
Court of Appeals for the
Tenth Circuit held that a firearm should be suppressed on grounds that it was inadmissible as the
'fruit' of a statement obtained without Miranda warnings. United States v.
Patane , 304 F. 3d 1013,
1014 (10th Cir. 2002). On June 28, 2004, the Supreme Court issued its opinion reversing the circuit
court's decision and remanding the case. The Court held that a failure to give Miranda
warnings
does not require the exclusion of physical evidence derived from a suspect's unwarned but voluntary
statements. The Court reasoned that since Miranda warnings were designed to protect
a criminal
defendant's rights under the Fifth Amendment and the Fifth Amendment forbids compelling a
defendant to testify against himself at trial, the introduction of physical evidence
obtained as a result
of voluntary statements given without Miranda warnings does not violate the Fifth
Amendment.
United States v. Patane , 542 U.S. __, 72 U.S.L.W. 4643 (June 28, 2004) (No. 02-1183).
In Seibert , the Missouri Supreme Court held that Mirandized
confessions following a prior
intentional violation of Miranda are inadmissible in court. On June 28, 2004, the
Supreme Court
issued an opinion affirming the lower court's decision. In so doing the Court held that when police
officers deliberately withhold Miranda warnings, consequent statements are inadmissible
even if
Miranda warnings are later administered, because the statements cannot be considered
voluntary.
Missouri v. Seibert , 542 U.S. __, 72 U.S.L.W. 4634 (June 28, 2004)(No. 02-1371).
However, the
Court left the door open for the possible admission of these statements when the withholding of the
Miranda warnings is unintentional.
A third case, United States v. Fellers , originally raised a Miranda issue,
but it was disposed by
the Court on Sixth Amendment right to counsel grounds.
