United States v. Mandujano

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United States v. Mandujano
Seal of the United States Supreme Court.svg
Argued November 5, 1975
Decided May 19, 1976
Full case nameUnited States v. Mandujano
Docket nos. 74-754
Citations 425 U.S. 564 ( more )
96 S. Ct. 1768; 48 L. Ed. 2d 212
Prior history

United States District Court for the Western District of Texas, 365 F. Supp. 155 (W.D. Tex. 1973), Count 1, attempted distribution of heroin: Conviction (without use of Mandujano’s grand jury testimony). Count 2, making false representations: thrown out.

Contents

United States Court of Appeals for the Fifth Circuit, 496 F.2d 1050 (5th Cir. 1974), affirmed.
Subsequent history remanded to district court United States Court of Appeals for the Fifth Circuit 539 F.2d 106 (5th Cir. 1976)
Holding
It is not necessary to provide full Miranda warnings to a person called to testify before a grand jury and false statements given during that testimony may not be suppressed in a subsequent prosecution for perjury.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr.  · Potter Stewart
Byron White  · Thurgood Marshall
Harry Blackmun  · Lewis F. Powell Jr.
William Rehnquist  · John P. Stevens
Case opinions
Majority Burger, joined by White, Powell, Rehnquist
Concurrence Brennan, joined by Marshall
Concurrence Stewart, joined by Blackmun
Stevens took no part in the consideration or decision of the case.

United States v. Mandujano, 425 U.S. 564 (1976), was a United States Supreme Court case that determined that it is not necessary to provide full Miranda warnings to a person called to testify before a grand jury; and that false statements given during that testimony may not be suppressed in a subsequent prosecution for perjury. [1]

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions. Each year it agrees to hear about one hundred to one hundred fifty of the more than seven thousand cases that it is asked to review.

<i>Miranda</i> warning notification given by American police to criminal suspects in police custody advising them of their rights

In the United States, the Miranda warning is a type of notification customarily given by police to criminal suspects in police custody advising them of their right to silence; that is, their right to refuse to answer questions or provide information to law enforcement or other officials. These rights are often referred to as Mirandarights. The purpose of such notification is to preserve the admissibility of their statements made during custodial interrogation in later criminal proceedings.

A grand jury is a jury – a group of citizens – empowered by law to conduct legal proceedings and investigate potential criminal conduct, and determine whether criminal charges should be brought. A grand jury may subpoena physical evidence or a person to testify. A grand jury is separate from the courts, which do not preside over its functioning.

Background

In 1973, Roy Mandujano negotiated with an undercover narcotics officer to purchase an ounce of heroin for six hundred fifty dollars. The transaction was never completed. Mandujano was then called before the grand jury, where he testified regarding his familiarity of the heroin industry in San Antonio, Texas. He was not given Miranda warnings before testifying.

Heroin chemical compound

Heroin, also known as diamorphine among other names, is an opioid most commonly used as a recreational drug for its euphoric effects. Medically it is used in several countries to relieve pain or in opioid replacement therapy. Heroin is typically injected, usually into a vein; however, it can also be smoked, snorted or inhaled. The onset of effects is usually rapid and lasts for a few hours.

San Antonio City in Texas, United States

San Antonio, officially the City of San Antonio, is the seventh-most populous city in the United States, and the second-most populous city in both Texas and the Southern United States, with more than 1.5 million residents. Founded as a Spanish mission and colonial outpost in 1718, the city became the first chartered civil settlement in present-day Texas in 1731. The area was still part of the Spanish Empire, and later of the Mexican Republic. Today it is the state's oldest municipality.

After his testimony, Mandujano was arrested for 1) attempted distribution of heroin and 2) perjury, but the United States District Court for the Western District of Texas suppressed the grand jury statements on the grounds that Mandujano was entitled to Miranda warnings before his testimony. Thus, the perjury charge was thrown out; however, Mandujano was convicted of the distribution charge. The United States Court of Appeals for the Fifth Circuit affirmed the decision to throw out the perjury charges on June 28, 1974. [2]

United States District Court for the Western District of Texas

The United States District Court for the Western District of Texas is a federal district court. The court convenes in San Antonio with divisions in Austin, Del Rio, El Paso, Midland, Pecos, and Waco. It has jurisdiction in over 50 Trans-Pecos, Permian Basin, and Hill Country counties of the U.S. state of Texas. This district covers over 92,000 square miles (240,000 km2) and seven divisions.

United States Court of Appeals for the Fifth Circuit federal court

The United States Court of Appeals for the Fifth Circuit is a federal court with appellate jurisdiction over the district courts in the following federal judicial districts:

Supreme Court Decision

The decisions by the District Court and Appellate Court to throw out the perjury charges were reversed and remanded by the Supreme Court. The Supreme Court determined that the grand jury is an integral part of the United States constitutional heritage which was brought with the common law. Furthermore, the grand jury serves as a barrier to reckless or unfounded charges.

Common law law developed by judges

In law, common law is that body of law derived from judicial decisions of courts and similar tribunals. The defining characteristic of “common law” is that it arises as precedent. In cases where the parties disagree on what the law is, a common law court looks to past precedential decisions of relevant courts, and synthesizes the principles of those past cases as applicable to the current facts. If a similar dispute has been resolved in the past, the court is usually bound to follow the reasoning used in the prior decision. If, however, the court finds that the current dispute is fundamentally distinct from all previous cases, and legislative statutes are either silent or ambiguous on the question, judges have the authority and duty to resolve the issue. The court states an opinion that gives reasons for the decision, and those reasons agglomerate with past decisions as precedent to bind future judges and litigants. Common law, as the body of law made by judges, stands in contrast to and on equal footing with statutes which are adopted through the legislative process, and regulations which are promulgated by the executive branch. Stare decisis, the principle that cases should be decided according to consistent principled rules so that similar facts will yield similar results, lies at the heart of all common law systems.

Miranda warnings are aimed at the evils seen by the Court as endemic to police interrogation of a person in custody. The Court considers it unlikely that a grand jury will abuse powers as police sometimes do. [1] Therefore, it is not necessary to provide full Miranda warnings to a person called to testify before the grand jury. Furthermore, false statements given during that testimony may not be suppressed in a subsequent prosecution for perjury.

Detention (imprisonment) removal of the freedom of liberty by a state

Detention is the process whereby a state or private citizen lawfully holds a person by removing his or her freedom or liberty at that time. This can be due to (pending) criminal charges preferred against the individual pursuant to a prosecution or to protect a person or property. Being detained does not always result in being taken to a particular area, either for interrogation or as punishment for a crime.

However, the Court did not decide whether a suspect questioned before a grand jury had a right to be warned of their Fifth Amendment right against self-incrimination. The defendant in this case received such a warning. [3]

Fifth Amendment to the United States Constitution Amendment guaranteeing rights related to trials and due process

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.

Fifth Circuit guidance on defining "attempt"

On August 19, 1974, the Fifth Circuit Court of appeals affirmed Mandujano's conviction of attempted distribution of heroin. [4] This case is worth noting for how the United States Court of Appeals for the Fifth Circuit summarized approaches to defining what constitutes an "attempt" to commit a crime. [5] [6] :683 Attempt has two elements, intent, and some conduct toward completion of the crime). [5] This opinion by the appellate court was not overturned by the Supreme Court decision.

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Branzburg v. Hayes, 408 U.S. 665 (1972), is a landmark United States Supreme Court decision invalidating the use of the First Amendment as a defense for reporters summoned to testify before a grand jury. The case was argued February 23, 1972 and decided June 29 of the same year. The reporter lost his case by a vote of 5-4. This case is cited for the rule that in federal courts, a reporter may not generally avoid testifying in a criminal grand jury, and it remains the only case in which the U.S. Supreme Court has considered the use of reporters' privilege.

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References

  1. 1 2 United States v. Mandujano, 425 U.S. 564 (1976).
  2. ↑ United States v. Mandujano, 496F.2d1050 ( 5th Cir. 1974).
  3. ↑ Mandujano, 425 U.S. at 592, n. 7.
  4. ↑ United States v. Mandujano, 499F.2d370 (5th Cir.1974).
  5. 1 2 Defining Attempts: Mandujano's Error, Duke University, Michael R. Fishman,
  6. ↑ Criminal Law - Cases and Materials, 7th ed. 2012, Wolters Kluwer Law & Business; John Kaplan, Robert Weisberg, Guyora Binder, ISBN   978-1-4548-0698-1,
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