But What About Miranda?
- Now we finally return to the actual case involving Ernesto Miranda. The previous four subsections were a lot of talking about the Fifth Amendment and the issues that surround the rights of the accused, and Warren tells us in this first paragraph that it's time to apply everything that's been said to the "cases before us" (Opinion.V.1).
- In that same paragraph, Warren skips to the end without even warning us of spoilers. He says that in all four cases (remember, Miranda v. Arizona is actually only one of four pretty similar cases, all at the same time), confessions were taken from defendants against their Fifth Amendment rights. In other words, all four cases screwed up.
- Warren first summarizes the Miranda case. In 1963, Ernesto Miranda was arrested in Phoenix, and was identified in a line-up by a witness. He's taken to an interrogation room and questioned by two police officers, and those officers admitted that they never told him he could have a lawyer.
- After two hours of questioning, the police emerge with a signed confession.
- Key point here: at the top of Miranda's confession was a typed statement saying that Miranda made the confession voluntarily, "with full knowledge of my legal rights, understanding any statement I make may be used against me" (Opinion.V.II). Do you think he had "full knowledge" of his rights? Hmm…
- Warren next summarizes the result of Miranda's initial trial, where the confession was used and he was sentenced to 20-30 years in prison for kidnapping and rape.
- The new result? The Supreme Court "reverses" (changes) the decision, saying that it's clear from testimony of the officers that Miranda was "not in any way apprised of his right to consult with an attorney and to have one present during the interrogation, nor was his right not to be compelled to incriminate himself effectively protected in any manner" (Opinion.V.4).
- Case closed.
- The case up next is called Vignera v. New York.
- A man named Michael Vignera was arrested in New York in 1960 in connection with a robbery. When questioned, Vignera admitted to the crime, and the detective was later asked whether he warned the defendant about the right to a lawyer, and (shocker) the answer was nope.
- Just like in Miranda v. Arizona, the Supreme Court says "we reverse" (Opinion.V.7). Same reasons here—no steps were taken to protect Vignera's Fifth Amendment rights.
- Another case down, except that Vignera probably wondered why it isn't called the Vignera Warning.
- Case #3 is Westover v. United States. In 1963 a man named Carl Westover was arrested in Kansas City and charged with robbery.
- He was interrogated three separate times, by the police and the FBI, which resulted in a signed confession. Once again, no mention anywhere of Westover being warned of his constitutional rights.
- The Supreme Court reverses again. They say that Westover was interrogated over a period of 14 hours, and was never told he could remain silent or talk with a lawyer.
- Remember, Warren stated earlier in this Opinion that we really don't know what kind of pressures people in custody could be put under without those rights; it could result in a forced confession.
- The final case, California v. Stewart, wraps up this subsection. Roy Stewart was arrested for robbery in 1963.
- Stewart was kept for five days, and interrogated nine different times.
- We know you'll be amazed to hear this, but Stewart was never warned about his%