Case Summary - Miranda v. Arizona

Facts

The Supreme Court’s decision in Miranda v. Arizona addressed four different cases involving custodial interrogations. 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.

Miranda v. Arizona: Miranda was arrested at his home and taken in custody to a police station where he was identified by the complaining witness. He was then interrogated by two police officers for two hours, which resulted in a signed, written confession. At trial, the oral and written confessions were presented to the jury. Miranda was found guilty of kidnapping and rape and was sentenced to 20-30 years imprisonment on each count. On appeal, the Supreme Court of Arizona held that Miranda’s constitutional rights were not violated in obtaining the confession.
Vignera v. New York: Vignera was picked up by New York police in connection with the robbery of a dress shop that had occurred three days prior. He was first taken to the 17th Detective Squad headquarters. He was then taken to the 66th Detective Squad, where he orally admitted the robbery and was placed under formal arrest. He was then taken to the 70th Precinct for detention, where he was questioned by an assistant district attorney in the presence of a hearing reporter who transcribed the questions and answers. At trial, the oral confession and the transcript were presented to the jury. Vignera was found guilty of first degree robbery and sentenced to 30-60 years imprisonment. The conviction was affirmed without opinion by the Appellate Division and the Court of Appeals.
Westover v. United States: Westover was arrested by local police in Kansas City as a suspect in two Kansas City robberies and taken to a local police station. A report was also received from the FBI that Westover was wanted on a felony charge in California. Westover was interrogated the night of the arrest and the next morning by local police. Then, FBI agents continued the interrogation at the station. After two-and-a-half hours of interrogation by the FBI, Westover signed separate confessions, which had been prepared by one of the agents during the interrogation, to each of the two robberies in California. These statements were introduced at trial. Westover was convicted of the California robberies and sentenced to 15 years’ imprisonment on each count. The conviction was affirmed by the Court of Appeals for the Ninth Circuit.
California v. Stewart: In the course of investigating a series of purse-snatch robberies in which one of the victims died of injuries inflicted by her assailant, Stewart was identified as the endorser of checks stolen in one of the robberies. Steward was arrested at his home. Police also arrested Stewart’s wife and three other people who were visiting him. Stewart was placed in a cell, and, over the next five days, was interrogated on nine different occasions. During the ninth interrogation session, Stewart stated that he had robbed the deceased, but had not meant to hurt her. At that time, police released the four other people arrested with Stewart because there was no evidence to connect any of them with the crime. At trial, Stewart’s statements were introduced. Stewart was convicted of robbery and first-degree murder and sentenced to death. The Supreme Court of California reversed, holding that Stewart should have been advised of his right to remain silent and his right to counsel.

Issues

Whether “statements obtained from an individual who is subjected to custodial police interrogation” are admissible against him in a criminal trial and whether “procedures which assure that the individual is accorded his privilege under the Fifth Amendment to the Constitution not to be compelled to incriminate himself” are necessary.

Supreme Court holding

The Court held that “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.” As such, “the prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way.” The Court further held that “without proper safeguards the process of in-custody interrogation of persons suspected or accused of crime contains inherently compelling pressures which work to undermine the individual’s will to resist and to compel him to speak where he would otherwise do so freely.” Therefore, a defendant “must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires.” The Supreme Court reversed the judgment of the Supreme Court of Arizona in Miranda, reversed the judgment of the New York Court of Appeals in Vignera, reversed the judgment of the Court of Appeals for the Ninth Circuit in Westover, and affirmed the judgment of the Supreme Court of California in Stewart. Argued: Feb. 28, March 1 and 2, 1966 Decided: June 13, 1966 Vote: 5-4 Majority opinion written by Chief Justice Warren and joined by Justices Black, Douglas, Brennan, and Fortas. Dissenting opinion written by Justice Harlan and joined by Justices Stewart and White. Dissenting in part opinion written by Justice Clark.

Follow-Up

Miranda v. Arizona: After Miranda’s conviction was overturned by the Supreme Court, the State of Arizona retried him. At the second trial, Miranda’s confession was not introduced into evidence. Miranda was once again convicted and sentenced to 20-30 years in prison.

Miranda

Recently, representatives of the Phoenix Police Museum had the opportunity to interview Carroll Colley, the detective assigned to the rape case that resulted in the Miranda Decision. This article is based on that interview and a written account from the AZPOST. Since the Court’s 1966 decision requiring the Miranda warnings, much has been written on the case’s judicial points; however, even police officers and attorneys who work with the results of the decision know few of the details of the actual crime and investigation. Miranda’s story began over a dozen years before his untimely death, in the downtown skid row section of Phoenix, Arizona, only a few blocks from where it ended. It is presented here by the police officer who made the investigation and arrest, and took the confession later ruled inadmissible as evidence by the U.S. Supreme Court. The crime involved a shy 18-year-old woman who had just finished her shift at the Paramount Theater in downtown Phoenix, Arizona, on March 2, 1963 at 11:45 pm. She boarded a bus for home located in northeast Phoenix. She exited the bus at 7^th Street and East Marlette. She had just started the 5-block walk home when a car pulled slowly from behind and stopped just in front of her. The suspect got out of the car and grabbed her, pressing a sharp object against her throat. He ordered, “Don’t scream, don’t scream and you won’t get hurt.” He forced her into the back seat of the car and tied her wrists and ankles with rope. He drove off as she cried and begged him to let her go. He would only respond,”Be quiet. Just be quiet and I won’t hurt you." Twenty minutes later, he arrived in a deserted area northeast of the city and raped the young victim. He then stole four dollars from the victim and turned to her stating, “Whether you tell your mother what happened or not is none of my business, but pray for me.” He drove her back to town where she ran to the home of a family member to report the crime. Uniformed officers responded and took the necessary reports and contacted detectives who took the initial report. The next morning, a 5-year veteran in the Crimes against Persons Detail, 27-year old Detective Carroll Cooley, was assigned to investigate this rape case. Cooley began with a routine interview with the victim who provided a description of a Mexican or Italian male with dark curly hair, combed back, about 25 years old, of average height and build wearing a white t-shirt and blue jeans. She stated the car was an old 4-door sedan, light green with light beige upholstery with vertical stripes, paint brushes on the floor and the smell of turpentine in the car. The investigation produced few results. A week passed with no substantial leads or possible suspects. Detectives checked marked similarity between the victim’s description and those of other attacks in Downtown Phoenix. The victim continued to work at her job but now had a family relative meet her at the bus stop to walk her home. A week after the attack, while waiting to walk the victim home, the male relative saw an old light-colored sedan with a single occupant drive slowly back and forth by the bus stop several times. He noted a license number of DFL-317. When the victim stepped off the bus he pointed to the car parked on the dark side street to see if that could be the suspect’s car. They walked towards the car and the victim thought it might be the same one, but the driver started the car and sped away. The male relative called the police who discovered the plate was registered to a 1958 Oldsmobile; however, the relative was sure it was a 1953 Packard. On March 11, Detective Cooley learned the male relative was unsure of the numbers of the plate but was sure of the letters DFL. Detective Cooley had MVD pull all their records on all Packard’s with the license numbers beginning with the DFL prefix. He found one registered in Mesa just one digit off from the number reported by the male relative. The next day Detectives Cooley and Young drove to the address of the registered owner, Twila Hoffman. The home was vacant, but neighbors stated the people who had lived there were Ernest Miranda and his wife, Twila. They had moved out a few days earlier. The neighbors noted that they used a truck marked “United Produce” to haul their items away. The detectives checked Miranda’s name with Mesa Police Department and learned he matched the suspect description. They also learned he had a juvenile record of assault with intent to commit rape in 1956, a juvenile arrest in Los Angels, California for robbery in 1957, as well as an arrest and conviction for auto theft in Tennessee in 1959 that resulted in a one-year sentence to federal prison. The detectives returned to downtown Phoenix and stopped at the United Produce Company where they learned that Ernest Miranda was employed there as a dockworker on the evening shift. United Produce did not have Miranda's home address, but they knew he had just moved. They had loaned him one of their trucks to move his family from Mesa to Phoenix. On Wednesday, March 13, the detectives continued their investigation by going to the downtown Phoenix Post Office to see if Miranda filed a change of address card. Their efforts paid off and they had his updated address. The detectives went to his address on West Mariposa and drove up to see a light grey 1953 Packard parked in the driveway with a plate of DFL-312. Cooley noted the interior matched the description provided by the victim. A woman, Twilla Hoffman, answered the door. She explained Miranda was asleep and went to awaken him. Several minutes later Miranda came to the door and the Detectives asked if he would come down to the police station so they could talk to him. Miranda agreed to go to the station and rode in the back seat of the car unrestrained and not under arrest. At the main police station, Miranda was taken to the Detective bureau and placed in the interview room with a two-way mirror for viewing line-ups. Detective Cooley began the interview. He explained to Miranda that another victim identified his license plate as being involved in the crime. Miranda denied knowing anything about the incident and claimed to be working that night at United Produce. Cooley continued taking with Miranda for over thirty minutes and his past record for assault. He stated that that Miranda may need psychiatric help and was the suspect in these cases. Miranda insisted he was innocent. Detective Cooley asked Miranda if he would consent to being viewed by the victims in a line-up with several other men of his general description. He agreed after the officers told him they would take him home if none of the victims could identify him. Detective Young brought in three prisoners form the City Jail to stand in the line-up while Cooley began to locate the victims. Only two victims could be located on a short notice. The victims arrived at the station shortly before 11:30 am. Miranda was told he could choose his position in the line by selecting one of the four large numbered cards that would be worn around their necks for identification. He chose #1, the first position in line. The victims were unable to positively identify the suspect. One victim believed that if she would hear his voice she might be sure. Cooley went in and told Miranda that he was identified by the victims. At that time Miranda responded, “Well, I guess I’d better tell you about it then.” Miranda confessed to both crimes and to using a nail file to conduct the assaults. The detectives asked if he would give them a written stated as to his actions. He agreed and was given a standard form. He written confession covered one kidnapping/rape/robbery of the 18-year old victim. Since attempted rape could not be established in the other case it would be the responsibly of the robbery detail and they did not want to risk jeopardizing Miranda’s successful prosecution by opening his written confession to attack because of the mention of other, unrelated crimes. After completing the statement, the first victim was brought into the room and Miranda was asked to state his name and if he recognized the women. He stated his name and said he did recognize her. After leaving the room, the victim stated she was positive Miranda was the man who raped her. She was sure the moment he spoke. The same occurred with the second victim. Det. Cooley told Miranda that he was under arrest for kidnap, rape and robbery and was handcuffed and booked in the fourth floor city jail. The detectives didn’t consider Miranda to be under arrest until this time. Prior to his verbal admissions, they would have had difficulty justifying holding Miranda if he had demanded that they either charge or release him. He was tried in Superior Court on June 18-19, 1963 based on the face -to- face identification, and part of his verbal confession was admitted as evidence. He was convicted and sentenced to 20-25 years on one incident in the Arizona State Prison at Florence. The U.S. Supreme Court disagreed, assuming the arrest to have been made at Miranda’s home. Within a week, he was tried on the second incident and was sentenced to 20-30 years in Arizona State Prison. Two years later a court appointed lawyer appealed the case to Arizona Supreme Court. He charged that Miranda’s constitutional right to legal counsel in one case was denied. The court ruled that since Miranda hadn’t asked for an attorney to assist or represent him at the time police questioned him, and since there was no legal requirement that he had to be advised of his rights to such counsel, the conviction would be upheld. After the failed appeal, John J. Flynn, agreed to try to have the case reviewed by the US Supreme Court at the request of the American Civil Liberties Union. The court agreed to a review in October 1965. The U.S. Supreme court reviewed three other cases that involved the same type of issues at the same time. The resulting decision was actually based on the Court’s review of all four cases, however, since Miranda vs. Arizona was the first case listed, if became generally know of as "The Miranda Decision." The U.S. Supreme Court returned the case to Maricopa County Superior court for retrial. Miranda’s conviction in the first original trial was not included in the appeal to the U.S. Supreme Court; therefore, the court's ruling was not applicable to that case. He still faced a 25-year prison sentence regardless of the outcome of his new trial. The other case was tried and the judge ruled that the victim’s s identification of Miranda was inadmissible on grounds that she had not been completely positive when she initially viewed the line-up. However, the jury found him guilty a second time and again the conviction was based heavily of his own admission and confession. He was sent to Arizona State Prison to serve both sentences concurrently. He remained there until paroled on April 28, 1975. The story did not end there. Miranda began hanging out at the old “duce”, the downtown Phoenix area where wholesale produce markets were once the hub of the area's commercial activity. He made money selling Police Miranda warning cards which he would autograph for a dollar. But his life ended on January 31, 1976 shortly after 6pm at the Amapola Bar at 233 South Second Street. He was playing cards in the bar with two other individuals. A fight erupted and Miranda was stabbed in the chest with a long bladed knife. The suspect was later located and read his Miranda rights for the murder of Earnest Miranda. The circle was completed; the victim becomes the suspect and his own original case influenced the interview of the suspect that killed him.

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