The Evolution Of Miranda: Law's Historical Transformation

The Miranda Warning, or Miranda Rights, became law in the United States on June 13, 1966, following the outcome of the Miranda v. Arizona case. The ruling established that criminal suspects must be advised of their rights before interrogation. The decision was based on the case of defendant Ernesto Miranda, who was accused of robbery, kidnapping, and rape in 1963. Miranda confessed to the crimes during a police interrogation, but his lawyers argued that he had not been informed of his right to remain silent or his right to an attorney. The U.S. Supreme Court overturned Miranda's conviction, ruling that his rights had been denied. As a result, law enforcement officials are now required to recite the Miranda Warning to suspects before any questioning, informing them of their right to remain silent, their right to an attorney, and that anything they say can be used against them in a court of law.

The Miranda Warning

The Background to Miranda v. Arizona

Ernesto Miranda was accused of robbery, kidnapping, and rape in Phoenix, Arizona, in 1963. After a two-hour interrogation, he signed a written confession to the crime, which included the statement: "this confession was made with full knowledge of my legal rights, understanding any statement I make may be used against me." However, Miranda's lawyer, Alvin Moore, appealed, stating that his client had not been informed of his right to silence or his right to an attorney, and that his confession was not made willingly.

The Decision

The American Civil Liberties Union took up Miranda's appeal, and the case went to the U.S. Supreme Court. The Court ruled to overturn Miranda's conviction on the grounds that he had been denied his rights. In the ruling, Chief Justice Earl Warren outlined a procedure for police officers to guarantee that all detainees are aware of their rights under the United States Constitution.

> "You have the right to remain silent. Anything you say can and will be used against you in a court of law. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you. Do you understand the rights I have just read to you? With these rights in mind, do you wish to speak to me?"

The specific language used in the warning may vary between jurisdictions, but the defendant's rights must be properly disclosed. The warning can be given orally or in writing, and officers must ensure the suspect understands what is being said, taking into account potential education levels and language barriers.

The Impact of the Miranda Warning

Exceptions to the Miranda Warning

The duty to administer the Miranda Warning arises only when police officers conduct custodial interrogations. It is not required as part of the arrest procedure or once an officer has probable cause to arrest. Additionally, there is a public safety' exception, which allows for unadvised statements to be admissible in cases where there is a great danger to public safety.

Ernesto Miranda's conviction

On March 2, 1963, an 18-year-old woman in Phoenix, Arizona, was kidnapped, raped, and robbed. The victim reported the crime to the Phoenix police, and days later, she and her cousin noticed a car driving slowly near the bus stop where she had been abducted. They reported the partial license plate number to the police, who tracked the car to Twila Hoffman, who lived in nearby Mesa, Arizona. Hoffman's boyfriend, 24-year-old Ernesto Miranda, had a prior record as a peeping tom.

Miranda voluntarily went to the police station for questioning and participated in a lineup. He was told he had been positively identified, at which point he was placed under arrest and interrogated. After two hours, Miranda confessed to the crimes of kidnapping and rape, writing out a confession under the words: "this confession was made with full knowledge of my legal rights, understanding any statement I make may be used against me."

Miranda was tried and convicted based on this confession. His court-appointed lawyer, Alvin Moore, appealed to the Arizona Supreme Court, arguing that Miranda had not been informed of his right to remain silent or his right to an attorney, and that his confession was not made willingly. The Arizona Supreme Court upheld the conviction, stating that Miranda had been aware of his rights.

The American Civil Liberties Union (ACLU) then took up Miranda's appeal, and the case went to the U.S. Supreme Court. The ACLU attorneys argued that Miranda's Sixth Amendment rights, which guarantee the rights of criminal defendants, and his Fifth Amendment rights against self-incrimination had been violated. They contended that because Miranda had not been informed of his rights, his confession was not obtained legally and should be thrown out.

In a landmark decision on June 13, 1966, the U.S. Supreme Court ruled in Miranda's favor, overturning his conviction. Chief Justice Earl Warren outlined a procedure for police officers to guarantee that all detainees are aware of their rights, now known as the Miranda Warning. The court's decision established the principle that all criminal suspects must be advised of their rights before interrogation.

Miranda was retried without his written confession, and in October 1966 or March 1967, he was convicted again based on testimony from his ex-girlfriend, Twila Hoffman. He was sentenced to 20-30 years in prison but was paroled in 1972.

Ernesto Miranda was fatally stabbed in a bar fight in Phoenix in January 1976. A suspect was charged with his murder but fled to Mexico and was never apprehended.

The Supreme Court ruling

On June 13, 1966, the U.S. Supreme Court ruled in favour of Ernesto Miranda in the case of Miranda v. Arizona, establishing the principle that all criminal suspects must be advised of their rights before interrogation.

The case against Miranda began in March 1963, when an 18-year-old woman in Phoenix, Arizona, was kidnapped, raped, and robbed. The victim and her cousin noticed a suspicious car driving slowly near the crime scene and reported the partial license plate to the police. The car belonged to Twila Hoffman, who lived with Miranda, a 24-year-old high school dropout with a lengthy police record. Miranda agreed to go to the police station for questioning and to appear in a lineup.

Miranda was interrogated for two hours without a lawyer present. At one point, the detectives brought the victim into the room, and Miranda identified her as the person he had raped. He then confessed to the crimes in a written statement, which he signed under the words: "This confession was made with full knowledge of my legal rights, understanding any statement I make may be used against me."

Miranda was convicted based on this confession. However, his lawyer, Alvin Moore, appealed to the Arizona Supreme Court, arguing that Miranda had not been informed of his right to remain silent or his right to an attorney, and that his confession was not made willingly. The Arizona Supreme Court upheld the conviction, stating that Miranda had been fully aware of his rights.

The American Civil Liberties Union (ACLU) then took up Miranda's case and appealed to the U.S. Supreme Court. They argued that Miranda's Sixth Amendment rights, which guarantee the rights of criminal defendants and the right to an attorney, and his Fifth Amendment rights against self-incrimination, had been violated. They contended that since Miranda had not been informed of his rights, his confession was not obtained legally and should be thrown out.

In a landmark decision, the Supreme Court, led by Chief Justice Earl Warren, ruled in favour of Miranda and overturned his conviction. Warren's written opinion outlined specific procedures that police officers must follow to ensure that all those detained are aware of their rights under the United States Constitution. These procedures became known as the Miranda Warning.

The Miranda Warning, finalized in 1968, reads as follows:

> "You have the right to remain silent. Anything you say can and will be used against you in a court of law. You have the right to an attorney. If you cannot afford an attorney, one will be provided for you. Do you understand the rights I have just read to you? With these rights in mind, do you wish to speak to me?"

The Supreme Court's ruling in Miranda v. Arizona had a significant impact on U.S. criminal procedure, ensuring that criminal suspects are informed of their constitutional rights during arrest and interrogation.

The Fifth Amendment

The Miranda Warning is a legal requirement in the United States, ensuring that individuals taken into custody are aware of their rights. The standard Miranda Warning states:

> "You have the right to remain silent. Anything you say can and will be used against you in a court of law. You have the right to speak to an attorney and to have an attorney present during any questioning. If you cannot afford a lawyer, one will be provided for you at government expense."

Each state may have slight variations in the wording of the Miranda Warning, but the Supreme Court's decision mandates that four key points must be clearly communicated:

• The right to remain silent: Defendants cannot be penalised for their silence in court. However, if a suspect has not been read their Miranda rights and remains silent, this "pre-Miranda" silence can be seen as unusual and suspect.
• Anything you say can be used against you in court: Those who give up their right to silence face the risk of their statements being used against them.
• The right to have an attorney present: Suspects have the right to legal counsel during interrogation. They must be clearly informed of this right and that they can request an attorney before answering any questions.
• If you cannot afford an attorney, one will be appointed to you: Suspects must be informed that a lawyer will be provided without charge if needed, ensuring they understand their right to legal counsel.

The Miranda Warning is a crucial safeguard for individuals' rights, ensuring that they are aware of their options and protecting them from self-incrimination.

The Sixth Amendment

Ernesto Miranda was accused of robbery, kidnapping, and rape in 1963. He confessed to the crimes during a police interrogation, but his conviction was overturned by the U.S. Supreme Court on the grounds that he had not been informed of his Sixth Amendment rights.

In the context of the Miranda case, the Sixth Amendment right to a lawyer was key. Miranda's lawyers argued that he had been denied his Sixth Amendment rights because he had not been informed of his right to a lawyer before interrogation. The Supreme Court agreed, ruling that Miranda's confession could not be used as evidence against him because he had not been properly informed of his rights.

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