Study Guide

Miranda v. Arizona Compare and Contrast

By Supreme Court of the United States

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  • Arizona Supreme Court

    Before the Miranda case became a nationwide attention-getter, it went through the normal progression of the U.S. court system: federal district court, then the court of appeals, and finally the U.S. Supreme Court. In this case, the court of appeals was the Arizona Supreme Court. Miranda's lawyer, Alvin Moore, pushed Miranda's case to this court in the hopes of getting his confession thrown out and the conviction overturned.

    The Arizona Supreme Court was therefore tackling the same issue that the U.S. Supreme Court would later—whether or not confessions could be used in court if suspects weren't told of their rights to silence and counsel. The Arizona Supreme Court's judges didn't agree that Miranda's confession should be thrown out. The judges focused on one central fact: that Miranda didn't request a lawyer when he was being questioned, and that therefore, his confession could be used as evidence.

    Remember, the current Miranda Warning says that you must be told of your right to a lawyer (which is your Sixth Amendment right) before any interrogation, because (a) you might not know about that right or (b) you might be too afraid to ask for a lawyer. But all of that wasn't actually enforced consistently until the case reached the U.S. Supreme Court.

  • Vignera v. New York

    Perceptive Shmoopers might notice that the Supreme Court case called Miranda v. Arizona actually includes three other cases. It's kind of like the court just lumped them all together since they deal with similar issues, and chose one case for the overall name.

    Actually, that's exactly what they did.

    In Vignera v. New York, Michael Vignera was arrested and questioned by the police, which resulted in his verbal confession. He was found guilty of robbery and sentenced to 30-60 years in jail (that's a big sentence for robbing a dress shop). Vignera was never told about his rights, so the question became whether the courts should be able to use his confession, since the Fifth Amendment protects us from having to be witnesses against ourselves.

    The Supreme Court reversed the decision of the New York court, which makes sense given how they ruled on Miranda v. Arizona.

  • Westover v. United States

    This case is lumped in with the Miranda v. Arizona ruling, because it deals with similar Fifth and Sixth Amendment rights issues. A man named Carl Westover was arrested and questioned about robberies in Kansas City and California. After hours of interrogation, by both police officers and the FBI, Westover signed confessions to each robbery. He was sentenced to 15 years in jail for each crime.

    The whole idea here is that we don't really know what goes on in these interrogations, since they're in private rooms with no lawyers present. In those situations, suspects might feel pressured to admit what they did. So, just like the Miranda v. Arizona and Vignera v. New York cases, the Supreme Court reversed the ruling against Westover, because they weren't convinced that he was made aware of his rights to silence and a lawyer.

  • California v. Stewart

    This is the last case within the Miranda v. Arizona Supreme Court text. Roy Stewart was accused of a few purse-snatching robberies. He was interrogated nine different times, each time alone with the police. During the ninth session, Stewart admitted that he robbed one of the victims who ended up dead from injuries during the event.

    As the Opinion of Miranda v. Arizona states, "nothing in the record specifically indicates whether Stewart was or was not advised of his right to remain silent or his right to counsel" (Opinion.V.15). Officers were questioned by the Supreme Court, and none said that they'd told Stewart about his rights. The Supreme Court said that without evidence that the suspect was informed of his rights, the confession couldn't be used in the trial.

  • Escobedo v. Illinois

    Let's face it—most people don't recognize Supreme Court case names and know what they were all about. But most people do see the results of these cases and recognize those. Escobedo v. Illinois is a great example of a case no one's heard of yet we see the effects of all the time.

    Mostly on cop shows on TV.

    Tell us if this sounds familiar: a guy or gal is being questioned in a holding cell, and they look smugly at the police officer and say "I ain't tellin' you nothin' until I get my lawyer." Most people know they can have a lawyer present during questioning, but where does that right come from? Technically the answer is "The Sixth Amendment to the Constitution," but it was the Escobedo v. Illinois case that really validated that Constitutional right.

    Danny Escobedo was accused of murder back in 1960, and wasn't allowed to see a lawyer even though he asked for one…a lot. After fourteen hours of interrogation, Escobedo said some stuff that made it seem like he was involved in the crime. He was convicted of the murder and appealed to the Illinois Supreme Court and then the U.S. Supreme Court.

    The Sixth Amendment to the Constitution says that "In all criminal prosecutions, the accused shall […] have the assistance of counsel for his defense." So, by denying Escobedo access to a lawyer ("counsel for his defense"), the police violated his Constitutional rights. Escobedo v. Illinois says the police can't deny you your right to a lawyer, but Miranda v. Arizona takes it one step further and says that the police must tell you about your right to a lawyer.

  • Gideon v. Wainwright

    This was the case that made sure everyone—rich, poor, or in between—gets a lawyer. That's right: even if you can't afford to pay for some dude or dudette in a suit to come help you in prison, you get one appointed for you at the state's expense.

    You can thank the Fourteenth Amendment for that. In debating the Gideon v. Wainwright case, the Supreme Court decided that people can't be denied their right to a lawyer (as stated in the Sixth Amendment) just because they can't afford one. The court referenced the Fourteenth Amendment, which says that everyone must be treated equally under the law. Part of being treated equally means there can't be different services available or unavailable to someone based on how much money they have.

    So here's how it went down:

    Clarence Gideon was accused of robbery in 1961, and showed up to court all by himself because he couldn't afford legal representation. He asked the court to give him a lawyer, and he even referenced his Constitutional right to an attorney. (There's someone who didn't sleep through government class.) The court refused. In jail, Gideon wrote his petition to the U.S. Supreme Court on prison stationery, and they accepted the case.

    Two years later, the Supreme Court made their decision: the right to a lawyer is a fundamental right under our Constitution, and that right applies to everyone equally, regardless of ability to pay. Of course, if you're wealthy, you can hire a slew of expensive attorneys who can probably out-argue an overworked public defender any day, but that's another issue.

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