Miranda vs Arizona Paper

There were four different cases that were addressed by the Supreme Court’s decision in Miranda v. Arizona. These cases involve custodial interrogations and in each of these cases, the defendant was cut off from the outside world while they were being interrogated in a room by the police officers, detectives, as well as prosecuting attorneys. In the four cases, not even one of the defendants was given a full and effective warning of his rights during the interrogation process. Furthermore, the questioning done in all the cases elicited oral admissions and, in three of them, signed statements that were admitted at trial. Miranda vs. Arizona (Facts):

While sleeping at his home, Miranda was arrested and taken into custody to a police station. The complaining witness identified him in a lineup and he was interrogated by two police officers. The interrogation lasted for hours which finally resulted to Miranda’s signing of a written confession. At trial, the oral and written confessions were presented to the jury and subsequently Miranda was found guilty of kidnapping and rape. He was sentenced to 20-30 years imprisonment on each count. He appealed to the Supreme Court of Arizona which held that Miranda’s constitutional rights were not violated in the course of obtaining the confession.

Vignera v. New York (Facts):
Vignera was taken into custody by NY police in connection with the robbery of a dress shop. The robbery occurred three days prior. He was interrogation in the Detective Squad headquarters where he orally admitted to the robbery and was placed under formal arrest. He was also questioned by the district attorney in the presence of a hearing reporter who wrote the questions as well as the answers provided by Vignera. The oral confession and the transcript were presented to the jury and Vignera was found guilty of first degree robbery and sentenced to 30-60 years of imprisonment.

Westover v. United States (Facts):
Westover was a suspect in two Kansas City robberies and was arrested by local police and taken to a local police station. The FBI also received a report that Westover was wanted on a felony charge in California. Westover was interrogated the night of the arrest and the next morning by local police. Then, FBI agents continued the interrogation at the station. After two and one-half hours of interrogation by the FBI, Westover signed separate confessions, which had been prepared by one of the agents during the interrogation, to each of the two robberies in California. These statements were introduced at trial. Westover was convicted of the California robberies and sentenced to 15 years’ imprisonment on each count. The conviction was affirmed by the Court of Appeals for the Ninth Circuit.

California v. Stewart (Facts):
In the course of investigating a series of purse-snatch robberies in which one of the victims died of injuries inflicted by her assailant, Stewart was identified as the endorser of checks stolen in one of the robberies. Steward was arrested at his home. Police also arrested Stewart’s wife and three other people who were visiting him. Stewart was placed in a cell, and, over the next five days, was interrogated on nine different occasions. During the ninth interrogation session, Stewart stated that he had robbed the deceased, but had not meant to hurt her. At that time, police released the four other people arrested with Stewart because there was no evidence to connect any of them with the crime. At trial, Stewart’s statements were introduced. Stewart was convicted of robbery and first degree murder and sentenced to death. The Supreme Court of California reversed, holding that Stewart should have been advised of his right to remain silent and his right to counsel.

The issue here is whether or not statements elicited from a suspect who was subjected to a custodial police interrogation without the police following the procedures which assure that the individual is accorded his privilege under the Fifth Amendment to the Constitution of the United States and not be compelled to incriminate himself are admissible in a criminal trial. The court held that unless the prosecution demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination it may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant. The Fifth Amendment serves to protect persons in all settings in which their freedom of action is curtailed in any significant way from being compelled to incriminate themselves.

The court further held that the defendant “must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires.” The reason is that “without the proper safeguards the process of in-custody interrogation of persons suspected or accused of crime contains inherently compelling pressures which work to undermine the individual’s will to resist and to compel him to speak where he would otherwise do so freely.” The judgment of the Supreme Court of Arizona in Miranda, the judgment of the New York Court of Appeals in Vignera, the judgment of the Court of Appeals for the Ninth Circuit in Westover, were all reversed by the Supreme Court.

I think Miranda Doctrine is indispensable especially here in the Philippines where most people are ignorant of their rights when they are arrested or taken into custody by police officers. Most of the time suspected criminals submit to the interrogation done to them without any lawyer present due to their level of education and ignorance to the law. There are many rogue policemen in the Philippines who take advantage of this ignorance. However, if such right is read to the accused during his arrest and he really understands, then it will lessen the abuse during the course of interrogation that the police officer may do.