IMPACT OF CASE ON SOCIETY AND LEGAL DEVELOPMENT 6
Brief explanation of the facts
In Miranda v. Arizona, 384 U.S. 436 (1966), Ernesto Miranda was arrested based on circumstantial evidence by the Arizona Police Department for the kidnapping and rape of a woman. The victim in a police lineup identified him and was interrogated for two hours. After the interrogation, Miranda signed a confession to the charges on a form. In the confession, Miranda swore that he made the statement out of his freewill and under no coercion, intimidation, promises of immunity, and he understood his legal rights and that any statement he makes may be used against him. However, Miranda was not informed of his right to an attorney or to remain silent because any statement he makes during interrogation may be used during trial. During trial, the prosecutors used the sworn statement as evidence, but the court appointed attorney objected to the use of the evidence, he cited that the confessions were made involuntarily and should be excluded (Burgan, 2007). The court overruled the attorney’s objection and Miranda was sentence to between 20 and 30 years for rape and kidnapping. Even after appealing to the Arizona Supreme Court, the ruling of the trial court was upheld since Miranda did not request for a lawyer. After appeal to the United States Supreme Court, the court ruled that the evidence was not admissible due to the coercive nature of the police interrogation, which violated the Fifth Amendment right to protection against self-incrimination and the sixth amendment right to a lawyer. Furthermore, the court ruled that confessions were only admissible if the defendant had been told of these rights and had waived them.
Explanation of the legal issues relevant to criminal law
The constraints of interrogation needed to protect a person’s constitutional rights should not cause unwarranted intrusion to a proper and efficient system of law enforcement. This is evident in the procedures of the Federal Bureau of Investigations (FBI) and the safeguards given in other jurisdictions. The context on incommunicado existing presently is inherently coercive and intimidating. It functions to undermine the right against self-incrimination. Unless sufficient precautionary measures are adopted to dispel the compulsive nature of custodial atmospheres, no confession obtained from the accused can be truly the outcome of free choice (Burgan, 2007).
The right against self-incrimination, which has a long history of development, is the key foundation of the American adversary system and guarantees to the person the right to remain silent unless he/she chooses otherwise as an exercise of free choice during custodial interrogations, official investigations and in court. The decision in Escobedo highlighted the need for safeguards to make police interrogations conform to the guidelines of this right (Stuart, 2008).
In the deficiency of other effective safeguards, certain procedures that safeguard the Fifth Amendment rights must be adhered to. This include informing the accused of the right to remain silent and any statement from him will be used in a court of law against him, informing him of his right to an attorney during interrogation and if poor one must be appointed by the state to represent him. In a case where interrogation is carried out in the absence of a lawyer and a statement is obtained, a heavy burden lies on the state to show that the defendant intelligently and willingly waived the privilege of an attorney.
Analysis of the court's holding and reasoning
Stuart (2008) argues that the case of Miranda and Arizona raised fundamental questions that touched on the premises of American criminal jurisprudence. These are the controls that society must consider consistent with the constitution in prosecuting persons for crime. More particularly, it deals with the admissibility of confessions derived from a person who is under police interrogation and the need for procedure that ensures that person is given his rights under the Fifth Amendment.
Citing the example of Escobedo v. Illinois, 378 U.S. 478 where police interrogated the defendant with the intention of obtaining evidence, the police did do not provide the legal safeguards of remaining silent or consulting his lawyer. In this case, the police confronted the defendant with an alleged accomplice who incriminated him of the crime, and after denying the accusation, he was arrested and taken for interrogated. While still handcuffed, the defendant was interrogated for four hours until he confessed to the crime. In this case, the defendant was denied consultation with his attorney and during trial, the admissibility of the confession was denied.
The court granted certiorari in the case and explored some aspects of the challenges presented by applying the right against self-incrimination during interrogation and offer firm constitutional guideline for the police and courts to adhere. The premise of the court’s ruling is not a creation in its jurisprudence, but it is an application of rules that have long been recognized and used in other circumstance. The Miranda decision, similar to the Escobedo case is a clarification of the fundamental rights that are protected in the constitution. According to Burgan (2007), the right against self-incrimination and the right to an attorney were jeopardized in both cases through official coercion. These rights were inserted into the constitution after many years of persecution and struggle. The constitutional issue determined in this case is the admissibility of statements derived from an accused when denied of his/her freedom in any significant manner. The defendant was interrogated in a room that cut him from the outside world and was not given any effective warning of his rights at the start of the interrogation (Stuart, 2008). These are salient characteristics of a police-dominated atmosphere. The statements in the absence of warnings of constitutional rights infringes on key constitutional rights.
Analysis of how culture influenced the court's decision
The coercive nature of interrogations carried out by the police contributed to the court’s decision. There were several police training manuals that were not given in the arguments and this contributed to the decision. During this period, the police could obtain confessions without warning them of their right against self-incrimination. This practice by law enforcement officers, as evidenced in the case of Escobedo contribute to the ruling.
The impact of this judicial ruling on the development of society and criminal law
The ruling has had significance on legal development and on the society. Opponents of the ruling argued that the decision would interfere with police work leading to criminals walking freely. This led to Congress passing a legislation in 1968 giving courts the ability to assess confessions case-by-case to determined wither they are admissible. The major contribution of this case is the introduction of Miranda rights, which were listed in the Majority Opinion (Burgan, 2007). The Miranda rights stipulated a that a suspect must be warned before interrogation that he had the privilege to remain silent and any statement from him can be used in a court of law and that he has the privilege of an attorney. If the defendant is indigent, the state will provide one. These rights have had significant impact because it prevents the police from using evidence derived from custodial investigations. Considering the coercive nature of police interrogations, the rights safeguard against self-incrimination.
References
Burgan, M. (2007). Miranda v. Arizona: The rights of the accused. Minneapolis, Minn: Compass Point Books.
Miranda v. Arizona. 384 U.S. 436 (1966).
Stuart, G. L. (2008). Miranda: The story of America's right to remain silent. Tucson: University of Arizona Press.