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            The case, Miranda v. Arizona, can be considered a
landmark and controversial case in U.S. Supreme Court history. Miranda v. Arizona helped establish what
is now known as the “Miranda Warning,” a statement required of all law
enforcement officials to be given to criminal suspects in custody before they
are interrogated. This warning ensures that suspects being interrogated is
aware of their Fifth Amendment protection against self-incrimination, and that
they are aware of their right to have an attorney present or to have one appointed
to them. As I learned through extensive research, this decision by the Warren
court was widely criticized as being detrimental to the job of police officers
and possibly leading to an increase in crime.

Case Summary

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            In March of 1963,
Ernesto Miranda was arrested in Phoenix, Arizona for the kidnapping and rape of
an eighteen-year-old woman.1
Miranda was interrogated for two hours straight, until the police were able to
obtain a written confession from him for the rape charge. Miranda was also
identified by a witness in a line-up at the police station. The police officers
responsible for the interrogation never explicitly told Miranda of his right to
have an attorney present, of his right to remain silent and not incriminate
himself, or that his signed confession could be admitted as evidence at trial.
The written confession was admitted into trial despite Miranda’s lawyer arguing
against it, citing a failure on the police officer’s part in not informing
Miranda of his rights. Miranda was convicted for the the kidnapping and rape
charges and sentenced to serve 20-30 years in prison. Alvin Moore, Miranda’s
lawyer, appealed the case to the Arizona Supreme Court but they affirmed the trial
court’s decision and held that no rights had been violated.2
The case was appealed a second time to the United States Supreme Court and
granted a writ of certiorari, where it was heard alongside three other cases
pertaining to the same issue, Vignera v.
New York, Westover v. United States, and
California v. Stewart. “In each of these cases, the defendant was questioned by police
officers, detectives, or a prosecuting attorney in a room in which he was cut
off from the outside world. In none of these cases was the defendant given a
full and effective warning of his rights at the outset of the interrogation
process. In all the cases, the questioning elicited oral admissions and, in
three of them, signed statements that were admitted at trial.”3

The legal issue/question
before the U.S. Supreme Court was that of whether the Fifth Amendment’s
protection against self-incrimination applies to suspects during police
interrogations and whether it should be a requirement for police officers to
explicitly inform a suspect of their rights before questioning takes place. The
Arizona Supreme Court ruling was reversed by the U.S. Supreme Court in a 5-4
decision, with Justices Warren, Black, Douglas, and Fortas in favor, and
Justices Clark, Harlan, Stewart, and White dissenting. Chief Justice Earl
Warren, joined
by Justices Black, Douglas, Brennan, and Fortas, delivered the
majority opinion of the court stating, “there can be no doubt that the
Fifth Amendment privilege is available outside of criminal court proceedings,
and 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,” (Miranda v. Arizona 384
U.S. 436). The court held that an accused person in custody is under
significant pressure, and may not be able to resist the urge to speak, or
confess. Because of this, according to Chief Justice Warren, “proper safeguards”
must be put into place in order to properly allow suspects to exercise their
right to not self-incriminate, those proper safeguards being an explicit
explanation of their rights by the officer(s).  This also applies to the suspect’s right to an
attorney, and if the suspect requests an attorney, no questioning can take
place until the attorney is present.

            Justice Tom Clark wrote one of the multiple dissenting
opinions in which he claimed that the Court’s interpretation of the Fifth
Amendment in this case was too strict and that this would prohibit police
officers from doing their job effectively. Justice Clark also stated that just
because a suspect is not explicitly told his rights, does not mean their
confessions and statements during interrogation should be left out of evidence
in trial. Justice John Harlan also wrote a separate dissenting opinion where he
stated that the Fifth Amendment is not meant to prohibit pressure/distress on a
suspect and that there is no legal precedent requiring that suspects be
explicitly informed of their rights. Finally, Justice Byron White wrote a third
and final dissenting opinion in which he cited textualism claiming that the
original language of the Fifth Amendment contains no basis for the Court’s
ruling. Justice White stated, “the proposition that the privilege against
self-incrimination forbids in-custody interrogation without the warnings
specified in the majority opinion and without a clear waiver of counsel has no
significant support in the history of the privilege or in the language of the
Fifth Amendment.”4

Process Summary

            As previously
stated, this case first began in an Arizona trial court in the city of Phoenix.
Ernesto Miranda was arrested and charged with the kidnapping and rape of an eighteen-year-old
woman in March of 1963. After two hours of interrogation, the police officers
had acquired a singed confession from Miranda and the case was set for trial. Miranda’s
trial began in June of 1963. In the Arizona trial court, the signed confession
was used as the main piece of evidence in the case against Miranda, with
Miranda’s defense attorney not being able to do anything to stop it from being
admitted. With this evidence, the court found Ernesto Miranda guilty for both kidnapping,
count 1, and rape, count 2, and sentenced him to 20-30 years incarceration.
After this conviction, Miranda and his lawyer decided to appeal the case to the
Arizona Supreme Court. The Court decided to hear the case in April of 1965. The
case was heard En Banc by the Arizona Supreme Court who decided to affirm the Arizona
trial court’s decision, holding that the written confession could be admitted
as evidence.5 Finally,
Ernesto Miranda appealed the case to the U.S. Supreme Court and was granted a
writ of certiorari in 1966. In the U.S. Supreme Court, the Arizona Supreme Court
ruling was reversed, with the majority opinion holding that the Fifth Amendment
requires law enforcement officials to explicitly inform a suspect in custody of
their rights. Miranda was represented by attorney John Frank in his appeal to
the U.S. Supreme Court.

Application

            In my research, I
have found five aspects of this case that can be applied to material discussed
in class.

             First, is the application of the Legal Model
in the dissenting opinion by Justice Byron White. The legal model is one of multiple
models used by political scientists in order to determine how judges and justices
make decisions in court cases. The main idea behind the legal model is that
judges and justices will look only to the guidance of the law and what is
written in order to make their decisions, without letting their personal
beliefs and attitudes influence their decisions. As stated in the case summary
section of this paper, in his dissenting opinion, Justice White cites the
original language found in the Fifth Amendment of the U.S. Constitution in his
argument against the Court’s majority opinion. According to Justice White, the
text of the Fifth Amendment does not specifically state that a person being
held in custody and interrogated must be explicitly told of their rights to
protection from self-incrimination. This opinion applies perfectly to the
definition of “originalism” when it comes to court decision making, as Justice
White is looking to the guidance of the original text of the Fifth Amendment
and choosing to base his opinion and decision on how it is written exactly.

            Second,
we come to the notion of judicial activism. When looking at the majority
opinion of this case in particular, you get a sense of strong constitutional interpretation
from the five justices that vote in favor of reversing the Arizona Supreme Court
decision. While judicial activism has many definitions, in general it is
considered to be a doctrine or philosophy where judges and justices see fit to
develop new legal principles, using their own personal beliefs and views in
order to affect policy change, even if it goes against policy decisions by the other
branches of government. As stated previously, the text of the Fifth Amendment
does not explicitly state that law enforcement officials are required to read a
suspect in custody their rights, yet the majority opinion justices, in deciding
on this case, decided to interpret the language of the constitution in their
own way and create new policy for law enforcement officials across the country,
even though it would go against the wishes of some congressional members at the
time who sought to preserve state’s rights when it came to law enforcement policy.6
It is also not a surprise that this decision came from the Warren Court, which
is historically known for its liberal agenda and its increased use of judicial
activism for many landmark cases pertaining to civil rights and civil liberties
issues.

            Third,
we come to the notion of congressional response to the Court’s statutory and
constitutional interpretations. As we learned in class, congress can
oftentimes, when in disagreement with a court’s decision and interpretation of
law, choose to pass certain acts, statutes, or amendments in order to overrule
Supreme Court Decisions. Through my research, I found that following the decision
in Miranda v. Arizona, congress
elected to pass the “Omnibus Crime Control and Safe Streets Act” in 1968, which
allowed the Miranda decision to be ignored in federal criminal cases. Still,
this act was not strictly enforced, and future presidents instructed federal
officers to continue using Miranda Warnings when dealing with detained suspects
in federal cases. 6  Although the act has been largely ignored by
federal officials, the passing of this act demonstrates the power of the
legislative and executive branches over particularly controversial and
polarizing Supreme Court decisions. This also helps to show the power of our
system of government in the ability of the three branches to continuously
debate certain topics and affect policy changes but with a certain respect for
each other’s decisions.

            Fourth,
is “cue theory” and the factors that influence cert decisions. As we learned in
class, it can be very difficult discern exactly the type of cases that will be
granted a writ of certiorari by the U.S. Supreme Court. The official “Rule 10” is
very vague and explains little in how Supreme Court justices will decide to
hear a case. Yet, political scientists, over time, have learned that there are
many informal criteria that can lead to a case being granted a writ of certiorari,
one of those being cue theory. Cue theory is the idea that the likelihood of a
case being granted certiorari will increase by 80% if the case deals with civil
liberties issues, disagreements among judges of lower courts, or if the federal
government is a petitioner. And still, we also learned that many petitions to
the supreme court by convicted criminals are rarely granted cert as justices
see these cases as frivolous, with the prisoners just looking for any way out. Yet,
Ernesto Miranda’s case was granted a writ of certiorari, and in my opinion, a
large part of it has to do with cue theory and the ideology of the court at the
time. When studying Miranda v. Arizona closely,
it is clear that from the beginning the case had the makings of a historical
civil liberties issue, something which cue theory tells us increases the
chances of the case being granted a writ of certiorari. Even with the
petitioner being a convicted criminal, the liberal ideology of the Warren
court, with an already impressive history of landmark cases, such as Brown v. Board of Education, along with the
case’s strong civil liberties issues, was bound to be granted a writ of
certiorari by the Court.

            Fifth,
we come to the notion of first-level appellate court decision making. In class
we learned that appellate courts, at times, allow external factors to play a
role in the decisions that are made. In the case of Miranda v. Arizona, you can see how some of these external factors
could have played a role on the decision by the Arizona Supreme Court to affirm
the trial Court’s decision. While the Arizona Supreme Court is technically a
second level appellate court, in many ways, as a state court, its decision
making is influenced in large part by factors that do not play a role in U.S.
Supreme Court decision making. U.S. Supreme Court justices have the luxury of being
able able to make decisions on cases based in large part on their ideologies
and beliefs, if you choose to believe in the attitudinal model. This is because
U.S. Supreme Court justices are largely exempt from electoral and political
accountability, as well as having no ambition for higher office. The justices
on the Arizona Supreme Court, on the other hand, have to be somewhat more
careful in their decision making, often times following the ideology of the
governor that appointed them or choosing to not reverse as many lower court decisions
in order to prevent tension with other judges. Arizona justices can also more
easily fall prey to budget/salary cuts, a worsening of their working
conditions, and the possibility of not getting promoted to higher office. Because
of this, I believe their decision to affirm the trial court’s ruling in the
Ernesto Miranda case could have been somewhat affected by these external
decision-making factors that plague many of the courts below the U.S. Supreme Court.

Conclusion

            In
conclusion, it is clear that this Supreme Court case will go down in history as
yet another landmark decision for the Warren Court. Yet it also clearly had a
very polarizing effect on the public.

1
Markman, Stephen J. 1986.
“Miranda v. Arizona: Historical Perspective.” American Criminal Law
Review 24 (2): 193-242.

2
“Miranda v. Arizona.” Oyez.
https://www.oyez.org/cases/1965/759 (December 12, 2017).

3
“Facts and Case Summary –
Miranda v. Arizona.” United States Courts.
http://www.uscourts.gov/educational-resources/educational-activities/facts-and-case-summary-miranda-v-arizona
(December 12, 2017).

 

4
“Miranda v. Arizona 384 U.S. 436 (1966).” Justia Law. https://supreme.justia.com/cases/federal/us/384/436/case.html
(October 30, 2017)

5
“State v. Miranda, 401 P.2d
721, 98 Ariz. 18 – CourtListener.Com.” CourtListener.
https://www.courtlistener.com/opinion/1297557/state-v-miranda/ (December 12,
2017).

6
Ley, Aaron J.; Verhovek, Gordie.
2014. “The Political Foundations of Miranda v. Arizona and the Quarles Public
Safety Exception.” Berkeley Journal of Criminal Law 19 (2):
206-251.

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