- [Narrator] In the 1960s, Miranda versus Arizona
was a huge victory for individual rights.
The case established a set of arrest procedures,
including the famous right to remain silent
that Americans now take for granted.
Miranda was a consolidation of four cases.
Ernesto Miranda confessed after questioning
by Arizona Police
while he was in custody at a police station.
Before confessing, Miranda wasn't advised
of his right to counsel.
At trial, his confession was admitted
and a jury convicted him of kidnapping and rape.
The Supreme Court of Arizona affirmed Miranda's conviction.
Like Miranda, defendants Michael Vignera and Carl Westover
confessed to crimes after extensive custodial interrogations
without being notified of their rights.
Their convictions were affirmed.
However, the Supreme Court of California
reversed Roy Allen Stewart's conviction
because the record was silent
on whether he had been advised of his rights.
The United States Supreme Court accepted these four cases
to determine what kinds
of custodial interrogation procedures were required
to adequately safeguard the Fifth Amendment right
against self-incrimination.
The court held that without certain hallmark warnings
regarding the right to remain silent
and the right to counsel,
statements made during custodial interrogation
were inadmissible at trial.
Writing for a five-justice majority,
Chief Justice Warren concluded
that prosecutors couldn't use statements
from custodial interrogations
without procedural safeguards.
Custodial interrogation occurs
when law enforcement officers question a person
who has been arrested and taken into custody,
or otherwise deprived of freedom of action
in any significant way.
Warren described custodial interrogation
as inherently coercive.
Cutting suspects off from contact with the outside world
creates an environment ripe for intimidation.
Acting within a closed, hostile environment,
police officers can prey upon individual weaknesses
at the expense of individual liberties.
The risk of psychological intimidation was plain
in several of the consolidated cases here.
For example, Miranda suffered from mental illness,
and Stewart had dropped out of school in the sixth grade.
Due to these concerns,
the Constitution requires a number of procedural safeguards
that relieve some of the pressure
put upon people in custodial interrogation.
Prior to any questioning while in custody,
a person must be informed of the right to remain silent
and that anything said can be used as evidence of guilt.
The arrestee must also be notified
of the right to an attorney,
and that if the arrestee can't pay for an attorney
one will be provided for free.
Any waiver of these rights must be voluntary.
If a person refuses to be questioned at any point,
law enforcement can't continue the questioning.
The fact that a person answers some questions
doesn't mean the person waives the right
to consult with an attorney
or to stop the interrogation at a later point.
After establishing these principles,
the court held that the statements of all four men
were inadmissible.
The court reversed the convictions of Miranda,
Vignera, and Westover,
and then affirmed the California Supreme Court's
reversal of Stewart's conviction.
Justice Clark dissented from the court's judgment
as to the reverse convictions,
and concurred in the judgment on Stewart.
Lacking empirical evidence
on the impact of the court's procedure safeguards,
Clark worried the majority had gone too far.
Clark would've employed a totality-of-the-circumstances test
to evaluate whether each statement was voluntary.
Justice Harlan, joined by Justices Stewart
and White, dissented.
The majority's procedures
discouraged any kind of confession.
Even if the Fifth Amendment
applied to pre-trial custodial interrogations,
it hardly supported the majority's strict procedures.
Legislative reform could craft a better solution
and would be supported by empirical data
on the effect of any new procedures
on law enforcement practice.
Justice White also wrote his own dissent.
In White's view, no Fifth Amendment jurisprudence
supported the majority's procedures.
While it frequently fell to the court to make new law,
there was no logical basis
for assuming that custodial interrogations
were inherently coercive,
or that the majority's procedures
would render the statements voluntary.
Moreover, the majority's procedures
could weaken criminal law enforcement.
Just two years later,
Richard Nixon advocated reversing Miranda
in his 1968 presidential campaign.
He supported Congress's passing
of the Omnibus Crime Control and Safe Streets Act of 1968,
which purported to abolish Miranda in the federal system.
In Dickerson versus United States,
the court eventually struck down the law
and ruled that Miranda warnings
were still constitutionally required in federal cases.