Miranda v. Arizona

Case History Prior to Miranda v. Arizona

Prior to Miranda v. Arizona, the U.S. Supreme Court, then headed by Chief Justice Earl Warren, applied the due process voluntariness test in cases requiring regulation of police interrogation practices. The Court derived this test from a common-law rule that prohibited the use of involuntary confessions at trial. The Court's move toward protecting citizens from the perceived harm of police interrogation involved two cases: Messiah v. United States, 377 US. 201 (1964), and Escobedo v. Illinois, 378 US. 478 (1964). In the case of Messiah, the Court mandated that any incriminating statements deliberately elicited from an indicted accused in the absence of counsel must be excluded. This was an important, yet limited, decision by the Court in that most police interrogations occur before the indictment phase begins. In Escobedo, the Court further applied the Sixth Amendment protections to preindictment interrogation. Although the Escobedo decision was significant, its exact scope was ambiguous, causing confusion and generating a heated debate between legal analysts at the time. In order to clarify the ambiguity of the Escobedo decision, the U.S. Supreme Court accepted four cases for review, including Miranda v. Arizona.

Miranda v. Arizona

In 1965 the U.S. Supreme Court granted certiorari in four cases, Vignera v. New York, 384 U.S. 436 (1966), Westover v. United States, 384 U.S. 436 (1966), California v. Stewart, 384 U.S. 436 (1966), and Miranda v. Arizona, 384 U.S. 436 (1966). The Court granted certiorari to evaluate whether the four defendants' Fifth Amendment rights were violated by the admission of their confessions at trial, as well as to provide concrete constitutional guidelines for law enforcement agencies and courts to follow. All four cases began with similar circumstances in that the petitioners had been taken into custody and interrogated without being informed of their right to an attorney.

The case of Miranda v. Arizona began on the morning of March 13, 1963, when Ernesto Miranda, a poor Mexican immigrant with a prior criminal record, was taken by police to the station house, accused of the rape and kidnapping of an 18-year-old woman. Police placed Miranda in a lineup before the crime victim and interrogated him for more than 2 hours in an interrogation room. Eventually, Miranda confessed to the rape and kidnapping as well as to the robbery of a bank worker. Miranda signed a written confession typed by police that was later used against him at the [Page 526]trial in which a jury convicted him of kidnapping and rape. Miranda was sentenced to 20–30 years of imprisonment on each count, the sentences to run concurrently.

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