Wainwright v. Greenfield
Encyclopedia
Wainwright v. Greenfield, 474 U.S. 284
(1986), is a case in which the United States Supreme Court reversed the lower court's finding and overturned the petitioner's conviction, on the grounds that it was fundamentally unfair for the prosecutor
to comment during the court proceedings on the petitioner's silence invoked as a result of a Miranda warning
.
for Sarasota County, Florida
, the prosecutor argued that respondent's silence after receiving Miranda warnings was evidence of his sanity. The question presented is whether such use of a defendant's silence violates the Due Process
Clause of the Fourteenth Amendment
as construed in Doyle v. Ohio
(1976).
for sexual battery, respondent was given three separate Miranda warnings. Each time, he exercised his right to remain silent and requested to speak with an attorney before answering questions. Subsequently, the respondent pleaded not guilty by reason of insanity. During closing arguments in the Florida trial court, the prosecutor reviewed the police officer's testimony, over defense counsel's objection. The testimony described the occasions when respondent had exercised his right to remain silent. The prosecutor suggested that respondent's repeated refusals to answer questions without first consulting an attorney "demonstrated a degree of comprehension that was inconsistent with his claim of insanity".
Respondent then unsuccessfully sought habeas corpus
relief in Federal District Court, by suing the Florida Department of Corrections
and its secretary, Louie L. Wainwright
. The court affirmed the conviction, holding that the general rule precluding a prosecutor from commenting on a defendant's exercise of his right to remain silent did not apply to a case in which an insanity plea was filed.
.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1986), is a case in which the United States Supreme Court reversed the lower court's finding and overturned the petitioner's conviction, on the grounds that it was fundamentally unfair for the prosecutor
Prosecutor
The prosecutor is the chief legal representative of the prosecution in countries with either the common law adversarial system, or the civil law inquisitorial system...
to comment during the court proceedings on the petitioner's silence invoked as a result of a Miranda warning
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...
.
Summary of complaint
The respondent entered a plea of not guilty by reason of insanity to a charge of sexual battery. At his trial in the Circuit CourtCircuit court
Circuit court is the name of court systems in several common law jurisdictions.-History:King Henry II instituted the custom of having judges ride around the countryside each year to hear appeals, rather than forcing everyone to bring their appeals to London...
for Sarasota County, Florida
Florida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
, the prosecutor argued that respondent's silence after receiving Miranda warnings was evidence of his sanity. The question presented is whether such use of a defendant's silence violates the Due Process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
Clause of the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
as construed in Doyle v. Ohio
Doyle v. Ohio
Doyle v. Ohio, , is a United States Supreme Court case regarding the Due Process rights of the Fourteenth Amendment.-Holding:The Supreme Court held that the criminal defendant's silence in response to a Miranda warning cannot be construed to imply an admission.-See also:*List of United States...
(1976).
Circumstances
After his arrest in FloridaFlorida
Florida is a state in the southeastern United States, located on the nation's Atlantic and Gulf coasts. It is bordered to the west by the Gulf of Mexico, to the north by Alabama and Georgia and to the east by the Atlantic Ocean. With a population of 18,801,310 as measured by the 2010 census, it...
for sexual battery, respondent was given three separate Miranda warnings. Each time, he exercised his right to remain silent and requested to speak with an attorney before answering questions. Subsequently, the respondent pleaded not guilty by reason of insanity. During closing arguments in the Florida trial court, the prosecutor reviewed the police officer's testimony, over defense counsel's objection. The testimony described the occasions when respondent had exercised his right to remain silent. The prosecutor suggested that respondent's repeated refusals to answer questions without first consulting an attorney "demonstrated a degree of comprehension that was inconsistent with his claim of insanity".
Respondent then unsuccessfully sought habeas corpus
Habeas corpus
is a writ, or legal action, through which a prisoner can be released from unlawful detention. The remedy can be sought by the prisoner or by another person coming to his aid. Habeas corpus originated in the English legal system, but it is now available in many nations...
relief in Federal District Court, by suing the Florida Department of Corrections
Florida Department of Corrections
The Florida Department of Corrections, established in 1821, operates state prisons in Florida. It has its headquarters in Tallahassee.The Florida Department of Corrections operates the third largest state prison system in the United States...
and its secretary, Louie L. Wainwright
Louie L. Wainwright
Louie L. Wainwright was Secretary of the Florida Division of Corrections from 1962 to 1987, more than a quarter of a century. He is most famous for being the named respondent in two U.S. Supreme Court cases: Gideon v. Wainwright in which indigents are guaranteed an attorney, and Ford v...
. The court affirmed the conviction, holding that the general rule precluding a prosecutor from commenting on a defendant's exercise of his right to remain silent did not apply to a case in which an insanity plea was filed.
Decision
The Court held that the prosecutor's use of respondent's post-arrest, post-Miranda warnings silence as evidence of sanity violated the Due Process Clause of the Fourteenth AmendmentFourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
.