Dickerson v. United States
Encyclopedia
Dickerson v. United States, , upheld the requirement that the Miranda warning
be read to criminal
suspects, and struck down a federal statute that purported to overrule Miranda v. Arizona
.
The Court noted that neither party in the case advocated on behalf of the constitutionality of , the specific statute at issue in the case. Accordingly, it invited Paul Cassell, a former law clerk to Antonin Scalia
and Warren E. Burger
, to argue that perspective. Cassell was then a professor at the University of Utah
law school; he was later appointed a federal district court judge in that state.
, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by police may not be admitted in court unless the suspect first had certain warnings read to him beforehand. By now, these warnings are familiar to most Americans—the suspect has the right to remain silent during the interrogation, that anything he says to the police may be used against him in a court of law, that he has the right to legal counsel, and that if he cannot afford legal counsel a lawyer will be provided for him.
In 1968, two years after the Miranda decision, Congress passed a law that purported to overrule it. This statute, 18 U.S.C. § 3501, directed federal trial judges to admit statements of criminal defendants if they were made voluntarily, without regard to whether he had received the Miranda warnings. Under § 3501, voluntariness depended on such things as (1) the time between arrest
and arraignment
, (2) whether the defendant knew the crime for which he had been arrested, (3) whether he had been told that he did not have to talk to the police and that any statement could be used against him, (4) whether the defendant knew prior to questioning that he had the right to the assistance of counsel, and (5) whether he actually had the assistance of counsel during questioning. But the "presence or absence of any of" these factors "need not be conclusive on the issue of voluntariness of the confession." Because § 3501 was an act of Congress, it applied only to federal criminal proceedings and criminal proceedings in the District of Columbia.
Dickerson had been arrested for bank robbery and for using a firearm during a crime of violence, both federal crimes. He moved to suppress statements he made to the FBI because he had not received the Miranda warnings before he spoke to the FBI. The district court suppressed the statements, and so the government appealed
. The Fourth Circuit reversed the district court, reasoning that § 3501 had supplanted the requirement that the police give the Miranda warnings because Miranda was not a constitutional requirement and therefore Congress could overrule that decision by legislation. The Supreme Court then agreed to hear the case.
wrote the majority opinion, and began by briefly describing the historical backdrop against which the Miranda ruling had emerged. A suspect's confession had always been inadmissible if it had been the result of coercion
, or otherwise given involuntarily. This was true in England, and American law inherited that rule from England.
However, as time went on, the Supreme Court recognized that the Fifth Amendment
was an independent source of protection for statements made by criminal defendants in the course of police interrogation. "In Miranda, we noted that the advent of modern custodial police interrogation brought with it an increased concern about confessions obtained by coercion." Custodial police interrogation by its very nature "isolates and pressures the individual" so that he might eventually be worn down and confess to crimes he did not commit in order to end the ordeal. In Miranda, the Court had adopted the now-famous four warnings to protect against this particular evil.
Congress, in response, enacted § 3501. That statute clearly was designed to overrule Miranda because it expressly focused solely on voluntariness of the confession as a touchstone for admissibility. Did Congress have the authority to pass such a law? On the one hand, the Court's power to craft nonconstitutional supervisory rules over the federal courts exists only in the absence of a specific statute passed by Congress. But if on the other hand the Miranda rule was constitutional, Congress could not overrule it, because the Court alone is the final arbiter of what the Constitution requires. As evidence of the fact that the Miranda rule was constitutional in nature, the Court pointed out that many of its subsequent decisions applying and limiting the requirement arose in decisions from state courts, over which the Court lacked the power to impose supervisory nonconstitutional rules. Furthermore, although the Court had previously invited legislative involvement in the effort to devise prophylactic measures for protecting criminal defendants against overbearing tactics of the police, it had consistently held that these measures must not take away from the protections Miranda had afforded.
Finally, 34 years after the original decision, the Court was loath to overrule Miranda. Typically, the Court overrules constitutional decisions only when their doctrinal underpinnings have eroded. The Court felt that this was not the case in Miranda. "If anything, our subsequent cases have reduced the impact of the Miranda rule on legitimate law enforcement while reaffirming the decision's core ruling that unwarned statements may not be used as evidence in the prosecution's case in chief." The Miranda rule did not displace the voluntariness inquiry.
Scalia described the majority's decision as an unprincipled compromise between justices who believed Miranda was a constitutional requirement and those who disagreed. He noted that the majority did not state outright that the Miranda warning is a constitutional requirement, but merely that it is "constitutionally based." Scalia further criticized the majority for implying that Congress has no power to override judicially-imposed safeguards of constitutional rights (Marbury v. Madison
having settled that Congress may not override judicial interpretations of the Constitution).
Miranda warning
The Miranda warning is a warning given by police in the United States to criminal suspects in police custody before they are interrogated to preserve the admissibility of their statements against them in criminal proceedings. In Miranda v...
be read to criminal
Criminal law
Criminal law, is the body of law that relates to crime. It might be defined as the body of rules that defines conduct that is not allowed because it is held to threaten, harm or endanger the safety and welfare of people, and that sets out the punishment to be imposed on people who do not obey...
suspects, and struck down a federal statute that purported to overrule Miranda v. Arizona
Miranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
.
The Court noted that neither party in the case advocated on behalf of the constitutionality of , the specific statute at issue in the case. Accordingly, it invited Paul Cassell, a former law clerk to Antonin Scalia
Antonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
and Warren E. Burger
Warren E. Burger
Warren Earl Burger was the 15th Chief Justice of the United States from 1969 to 1986. Although Burger had conservative leanings, the U.S...
, to argue that perspective. Cassell was then a professor at the University of Utah
University of Utah
The University of Utah, also known as the U or the U of U, is a public, coeducational research university in Salt Lake City, Utah, United States. The university was established in 1850 as the University of Deseret by the General Assembly of the provisional State of Deseret, making it Utah's oldest...
law school; he was later appointed a federal district court judge in that state.
Background
In Miranda v. ArizonaMiranda v. Arizona
Miranda v. Arizona, , was a landmark 5–4 decision of the United States Supreme Court. The Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant...
, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by police may not be admitted in court unless the suspect first had certain warnings read to him beforehand. By now, these warnings are familiar to most Americans—the suspect has the right to remain silent during the interrogation, that anything he says to the police may be used against him in a court of law, that he has the right to legal counsel, and that if he cannot afford legal counsel a lawyer will be provided for him.
In 1968, two years after the Miranda decision, Congress passed a law that purported to overrule it. This statute, 18 U.S.C. § 3501, directed federal trial judges to admit statements of criminal defendants if they were made voluntarily, without regard to whether he had received the Miranda warnings. Under § 3501, voluntariness depended on such things as (1) the time between arrest
Arrest
An arrest is the act of depriving a person of his or her liberty usually in relation to the purported investigation and prevention of crime and presenting into the criminal justice system or harm to oneself or others...
and arraignment
Arraignment
Arraignment is a formal reading of a criminal complaint in the presence of the defendant to inform the defendant of the charges against him or her. In response to arraignment, the accused is expected to enter a plea...
, (2) whether the defendant knew the crime for which he had been arrested, (3) whether he had been told that he did not have to talk to the police and that any statement could be used against him, (4) whether the defendant knew prior to questioning that he had the right to the assistance of counsel, and (5) whether he actually had the assistance of counsel during questioning. But the "presence or absence of any of" these factors "need not be conclusive on the issue of voluntariness of the confession." Because § 3501 was an act of Congress, it applied only to federal criminal proceedings and criminal proceedings in the District of Columbia.
Dickerson had been arrested for bank robbery and for using a firearm during a crime of violence, both federal crimes. He moved to suppress statements he made to the FBI because he had not received the Miranda warnings before he spoke to the FBI. The district court suppressed the statements, and so the government appealed
Interlocutory appeal
An interlocutory appeal , in the law of civil procedure, is an appeal of a ruling by a trial court that is made before the trial itself has concluded. Most jurisdictions generally prohibit such appeals, requiring parties to wait until the trial has concluded before they challenge any of the...
. The Fourth Circuit reversed the district court, reasoning that § 3501 had supplanted the requirement that the police give the Miranda warnings because Miranda was not a constitutional requirement and therefore Congress could overrule that decision by legislation. The Supreme Court then agreed to hear the case.
Decision
Chief Justice RehnquistWilliam Rehnquist
William Hubbs Rehnquist was an American lawyer, jurist, and political figure who served as an Associate Justice on the Supreme Court of the United States and later as the 16th Chief Justice of the United States...
wrote the majority opinion, and began by briefly describing the historical backdrop against which the Miranda ruling had emerged. A suspect's confession had always been inadmissible if it had been the result of coercion
Coercion
Coercion is the practice of forcing another party to behave in an involuntary manner by use of threats or intimidation or some other form of pressure or force. In law, coercion is codified as the duress crime. Such actions are used as leverage, to force the victim to act in the desired way...
, or otherwise given involuntarily. This was true in England, and American law inherited that rule from England.
However, as time went on, the Supreme Court recognized that the Fifth Amendment
Fifth Amendment to the United States Constitution
The Fifth Amendment to the United States Constitution, which is part of the Bill of Rights, protects against abuse of government authority in a legal procedure. Its guarantees stem from English common law which traces back to the Magna Carta in 1215...
was an independent source of protection for statements made by criminal defendants in the course of police interrogation. "In Miranda, we noted that the advent of modern custodial police interrogation brought with it an increased concern about confessions obtained by coercion." Custodial police interrogation by its very nature "isolates and pressures the individual" so that he might eventually be worn down and confess to crimes he did not commit in order to end the ordeal. In Miranda, the Court had adopted the now-famous four warnings to protect against this particular evil.
Congress, in response, enacted § 3501. That statute clearly was designed to overrule Miranda because it expressly focused solely on voluntariness of the confession as a touchstone for admissibility. Did Congress have the authority to pass such a law? On the one hand, the Court's power to craft nonconstitutional supervisory rules over the federal courts exists only in the absence of a specific statute passed by Congress. But if on the other hand the Miranda rule was constitutional, Congress could not overrule it, because the Court alone is the final arbiter of what the Constitution requires. As evidence of the fact that the Miranda rule was constitutional in nature, the Court pointed out that many of its subsequent decisions applying and limiting the requirement arose in decisions from state courts, over which the Court lacked the power to impose supervisory nonconstitutional rules. Furthermore, although the Court had previously invited legislative involvement in the effort to devise prophylactic measures for protecting criminal defendants against overbearing tactics of the police, it had consistently held that these measures must not take away from the protections Miranda had afforded.
Finally, 34 years after the original decision, the Court was loath to overrule Miranda. Typically, the Court overrules constitutional decisions only when their doctrinal underpinnings have eroded. The Court felt that this was not the case in Miranda. "If anything, our subsequent cases have reduced the impact of the Miranda rule on legitimate law enforcement while reaffirming the decision's core ruling that unwarned statements may not be used as evidence in the prosecution's case in chief." The Miranda rule did not displace the voluntariness inquiry.
Dissent
Justice Scalia disagreed with the majority's decision not to overrule Miranda. He disputed the notion that Miranda was a constitutional rule, pointing to several cases in which the Court had declined to exclude evidence despite the absence of warnings.Scalia described the majority's decision as an unprincipled compromise between justices who believed Miranda was a constitutional requirement and those who disagreed. He noted that the majority did not state outright that the Miranda warning is a constitutional requirement, but merely that it is "constitutionally based." Scalia further criticized the majority for implying that Congress has no power to override judicially-imposed safeguards of constitutional rights (Marbury v. Madison
Marbury v. Madison
Marbury v. Madison, is a landmark case in United States law and in the history of law worldwide. It formed the basis for the exercise of judicial review in the United States under Article III of the Constitution. It was also the first time in Western history a court invalidated a law by declaring...
having settled that Congress may not override judicial interpretations of the Constitution).
See also
- List of United States Supreme Court cases, volume 530
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume