Background
Innis was arrested in connection with an earlier robbery of a taxicab driver with a sawed-off shotgun. Upon arrest, Innis received his Miranda warnings, to which he responded that he understood his rights and wished to speak to an attorney. Innis was then placed in a police car to be driven to the central police station. The three officers placed with transporting Innis were instructed not to question or intimidate him in any way. On their way to the station, the officers began a discussion showing concern about the missing shotgun from the robbery. One of the officers stated that there were “a lot of handicapped children running around in this area” because a school for such children was located nearby, and “God forbid one of them might find a weapon with shells and they might hurt themselves.” Innis then interrupted them and, showing concern for the children, asked the officers to turn back so he could show them the weapon. As the officers searched for the weapon, Innis was again read his Miranda rights, to which he acknowledged understanding but nonetheless was concerned for the children in the area. At trial, Innis moved to suppress the shotgun and his statements. The lower court denied the motion to suppress, while the Rhode Island Supreme Court held Innis was entitled to a new trial.
The Rhode Island Supreme Court is the court of last resort in the U.S. State of Rhode Island and Providence Plantations. The Court consists of a Chief Justice and four Associate Justices, all selected by the Governor of Rhode Island from candidates vetted by the Judicial Nominating Commission. Each justice enjoys lifetime tenure and no mandatory retirement age, similar to Federal judges. Justices may be removed only if impeached for improper conduct by a vote of the Rhode Island House of Representatives and convicted by trial in the Rhode Island Senate.
Opinion of the Court
The court held that the Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent. So, “interrogation” under Miranda refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect. Here, there was no express questioning of Innis. The conversation between the two officers was, at least in form, nothing more than a dialogue between them to which no response from respondent was invited. This does not raise to the level of “functional equivalent” of questioning, since it cannot be said that the officers should have known that their conversation was reasonably likely to elicit an incriminating response from Innis. Under this standard, any knowledge that the police might have concerning unusual susceptibility of the defendant to a particular form of persuasion might be an important factor in determining whether the police should have known that their words or actions were reasonably likely to elicit an incriminating response from the suspect.
There is nothing to suggest that the officers were aware that respondent was peculiarly susceptible to an appeal to his conscience concerning the safety of handicapped children. In this case, Innis' statement were viewed as voluntary and thus not barred by the Fifth Amendment.
The Fifth Amendment to the United States Constitution addresses criminal procedure and other aspects of the Constitution. It was ratified in 1791 as part of the Bill of Rights. The Fifth Amendment applies to every level of the government, including the federal, state, and local levels, as well as any corporation, private enterprise, group, or individual, or any foreign government in regards to a US citizen or resident of the US. The Supreme Court furthered the protections of this amendment through the Due Process Clause of the Fourteenth Amendment.
The fact pattern in this case is similar to that in Brewer v. Williams , 430 U.S. 387 (1979), where police used their knowledge of Williams's deep religious beliefs to elicit an incriminating statement despite not formally questioning Williams. However, in Brewer, the state had already initiated formal judicial proceedings by obtaining an arrest warrant and arraigning Williams, thus triggering the protections of the Sixth Amendment right to counsel under the Massiah doctrine. By contrast, Innis was decided under the Fifth Amendment, since formal proceedings had not commenced.
Brewer v. Williams, 430 U.S. 387 (1977), is a decision by the United States Supreme Court that clarifies what constitutes "waiver" of the right to counsel for the purposes of the Sixth Amendment. Under Miranda v. Arizona, evidence obtained by police during interrogation of a suspect before he has been read his Miranda rights is inadmissible. Here, however, the defendant had been indicted in court and had asserted his desire to have counsel, thus his Sixth Amendment right to counsel had attached. At issue was whether a voluntary admission of incriminating facts in response to police statements made while the defendant was in custody and outside the presence of his lawyer constituted a waiver of this right to counsel.
The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.
Massiah v. United States, 377 U.S. 201 (1964), was a case in which the Supreme Court of the United States held that the Sixth Amendment to the United States Constitution prohibits the government from eliciting statements from the defendant about themselves after the point that the Sixth Amendment right to counsel attaches.
An arrest is the act of apprehending a person and taking them into custody, usually because they have been suspected of committing or planning a crime. After the person is taken into custody, they can be questioned further and/or charged. An arrest is a procedure in a criminal justice system.
Interrogation is interviewing as commonly employed by law enforcement officers, military personnel, and intelligence agencies with the goal of eliciting useful information. Interrogation may involve a diverse array of techniques, ranging from developing a rapport with the subject to outright torture.
The right to silence is a legal principle which guarantees any individual the right to refuse to answer questions from law enforcement officers or court officials. It is a legal right recognized, explicitly or by convention, in many of the world's legal systems.
Ernesto Arturo Miranda was a laborer whose conviction on kidnapping, rape, and armed robbery charges based on his confession under police interrogation was set aside in the landmark U.S. Supreme Court case Miranda v. Arizona, which ruled that criminal suspects must be informed of their right against self-incrimination and their right to consult with an attorney before being questioned by police. This warning is known as a Miranda warning.
Self-incrimination is the act of exposing oneself generally, by making a statement, "to an accusation or charge of crime; to involve oneself or another [person] in a criminal prosecution or the danger thereof". Self-incrimination can occur either directly or indirectly: directly, by means of interrogation where information of a self-incriminatory nature is disclosed; or indirectly, when information of a self-incriminatory nature is disclosed voluntarily without pressure from another person.
Missouri v. Seibert, 542 U.S. 600 (2004), is a decision by the Supreme Court of the United States that struck down the police practice of first obtaining an inadmissible confession without giving Miranda warnings, then issuing the warnings, and then obtaining a second confession. Justice David Souter announced the judgment of the Court and wrote for a plurality of four justices that the second confession was admissible only if the intermediate Miranda warnings were "effective enough to accomplish their object." Justice Anthony Kennedy wrote in a concurring opinion that the second confession should be inadmissible only if "the two-step interrogation technique was used in a calculated way to undermine the Miranda warning."
McNeil v. Wisconsin, 501 U.S. 171 (1991), held that the right to counsel secured by the Sixth Amendment and the right to counsel protected by Miranda v. Arizona are separate and distinct, such that invoking one does not implicitly invoke the other.
Garrity v. New Jersey, 385 U.S. 493 (1967), was a case in which the Supreme Court of the United States held that law enforcement officers and other public employees have the right to be free from compulsory self-incrimination. It gave birth to the Garrity warning, which is administered by investigators to suspects in internal and administrative investigations in a similar manner as the Miranda warning is administered to suspects in criminal investigations.
Fellers v. United States, 540 U.S. 519 (2004), is a United States Supreme Court case regarding the Sixth Amendment's right to counsel.
Berkemer v. McCarty, 468 U.S. 420 (1984), is a decision of the United States Supreme Court which ruled that, in the case of a person stopped for a misdemeanor traffic offense, once they are in custody, the protections of the Fifth Amendment apply to them pursuant to the decision in Miranda v. Arizona 384 U.S. 436 (1966). Previously, some courts had been applying Miranda only to serious offenses.
Edwards v. Arizona, 451 U.S. 477 (1981), is a decision by the United States Supreme Court holding that once a defendant invokes his Fifth Amendment right to counsel police must cease custodial interrogation. Re-interrogation is only permissible once defendant's counsel has been made available to him, or he himself initiates further communication, exchanges, or conversations with the police. Statements obtained in violation of this rule are a violation of a defendant's Fifth Amendment rights.
Berghuis v. Thompkins, 560 U.S. 370 (2010), is a landmark decision by the United States Supreme Court in which the Court considered the position of a suspect who understands their right to remain silent under Miranda v. Arizona and is aware that they have the right to remain silent, but does not explicitly invoke or waive the right.
Michigan v. Moseley, 423 U.S. 96 (1975), was a United States Supreme Court case in which the Court held that a criminal suspect's assertion of his right to remain silent after a Miranda warning does not preclude the police from re-Mirandizing him and questioning him about a different crime.
J. D. B. v. North Carolina, 564 U.S. 261 (2011), was a case in which the Supreme Court of the United States held that age is relevant when determining police custody for Miranda purposes. J. D. B. was a 13-year-old student enrolled in special education classes whom police had suspected of committing two robberies. A police investigator visited J. D. B. at school, where he was interrogated by the investigator, a uniformed police officer, and school officials. J. D. B. subsequently confessed to his crimes and was convicted. J. D. B. was not given a Miranda warning during the interrogation, nor an opportunity to contact his legal guardian.
New York v. Quarles, 467 U.S. 649 (1984), was a decision by the United States Supreme Court regarding the public safety exception to the normal Fifth Amendment requirements of the Miranda warning.
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