Jenkins v. Anderson

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Jenkins v. Anderson
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Argued January 8, 1980
Decided June 10, 1980
Full case nameJenkins v. Anderson, Warden
Citations447 U.S. 231 ( more )
100 S.Ct. 2124; 65 L. Ed. 2d 86; 1980 U.S. LEXIS 131
Holding
The Fifth Amendment is not violated by the use of prearrest silence to impeach a criminal defendant's credibility.
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
MajorityPowell, joined by Burger, White, Blackmun, Rehnquist
ConcurrenceStewart
ConcurrenceStevens
DissentMarshall, joined by Brennan

Jenkins v. Anderson, 447 U.S. 231 (1980), is a United States Supreme Court case regarding the Fifth Amendment right against self-incrimination.

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.

Contents

Holding

The Supreme Court held that a defendant's silence prior to a Miranda warning can be used by the prosecution to imply an admission. In Doyle v. Ohio , the Court held that silence after a Miranda warning cannot be used against the defendant to imply admission to guilt.

<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.

Doyle v. Ohio, 426 U.S. 610 (1976), is a United States Supreme Court case regarding the Due Process rights of the Fourteenth Amendment.

See also

Miranda v. Arizona, 384 U.S. 436 (1966), was a landmark decision of the United States Supreme Court. In a 5–4 majority, the Court held that both inculpatory and exculpatory statements made in response to interrogation by a defendant in police custody will be admissible at trial only if the prosecution can show that the defendant was informed of the right to consult with an attorney before and during questioning and of the right against self-incrimination before police questioning, and that the defendant not only understood these rights, but voluntarily waived them.

<i>United States Reports</i> official record of the rulings, orders, case tables, and other proceedings of the Supreme Court of the United States

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.

Further reading

International Standard Serial Number unique eight-digit number used to identify a print or electronic periodical publication

An International Standard Serial Number (ISSN) is an eight-digit serial number used to uniquely identify a serial publication, such as a magazine. The ISSN is especially helpful in distinguishing between serials with the same title. ISSN are used in ordering, cataloging, interlibrary loans, and other practices in connection with serial literature.

Related Research Articles

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.

Dickerson v. United States, 530 U.S. 428 (2000), upheld the requirement that the Miranda warning be read to criminal suspects and struck down a federal statute that purported to overrule Miranda v. Arizona (1966).

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.

Colorado v. Connelly, 479 U.S. 157 (1986), was a U.S. Supreme Court case that was initiated by Francis Connelly, who insisted that his schizophrenic episode rendered him incompetent, nullifying his waiver of his Miranda rights.

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.

Ohio v. Roberts, 448 U.S. 56 (1980), is a United States Supreme Court decision dealing with the Confrontation Clause of the Sixth Amendment to the United States Constitution.

Mitchell v. United States, 526 U.S. 314 (1999), is a United States Supreme Court case that considered two Fifth Amendment privileges related to a criminal defendant’s rights against self-incrimination in a Federal District Court. First, does a defendant who waives the guilty plea also waive the privilege during the sentencing phase of the trial? Secondly, may an adverse inference be drawn from the defendant's silence when the court is determining facts related to the crime which will affect the severity of the sentence?

Fellers v. United States, 540 U.S. 519 (2004), is a United States Supreme Court case regarding the Sixth Amendment's right to counsel.

United States v. Patane, 542 U.S. 630 (2004), was a United States Supreme Court case relating to Miranda warnings.

Griffin v. California, 380 U.S. 609 (1965), was a United States Supreme Court case in which the Court ruled, by a 6-2 vote, that it is a violation of a defendant's Fifth Amendment rights for the prosecutor to comment to the jury on the defendant's declining to testify, or for the judge to instruct the jury that such silence is evidence of guilt.

Montejo v. Louisiana, 556 U.S. 778 (2009), is a 5–4 decision by the United States Supreme Court that overruled the Court's decision in Michigan v. Jackson. The case concerned the validity of a defendant's waiver of his right to counsel during a police interrogation. In reversing Jackson, the Court said such a waiver was valid.

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.

Rhode Island v. Innis, 446 U.S. 291 (1980), is a decision by the United States Supreme Court that clarifies what constitutes "interrogation" for the purposes of Miranda warnings. Under Miranda v. Arizona, police are forbidden from interrogating a suspect once he has asserted his right to counsel under the Sixth Amendment. In Innis, the court held that interrogation is not just direct questioning but also its "functional equivalent"; namely, "any words or actions on the part of the police ... that the police should know are reasonably likely to elicit an incriminating response."

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.

Withrow v. Williams, 507 U.S. 680 (1993), was a United States Supreme Court case in which the Court held that Fifth Amendment Miranda v. Arizona arguments can be raised again in federal habeas corpus proceedings, even if a criminal defendant had a fair chance to argue those claims in state court. The Court rejected the state's argument that Stone v. Powell, a case holding the opposite in the context of Fourth Amendment claims on habeas review, applied in Williams' 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.