Dickerson v. United States

''Dickerson v. United States'', 530 U.S. 428 (2000), upheld the requirement that the Miranda warning be read to criminal suspects and struck down a federal statute that purported to overrule ''Miranda v. Arizona'' (1966).

''Dickerson'' is regarded as a significant example of a rare departure by the Court from the principle of party presentation. The Court noted that neither party in the case advocated on behalf of the constitutionality of 18 U.S.C. § 3501,. the specific statute at issue in the case. Accordingly, it invited Paul Cassell, a former law clerk to Antonin Scalia and Warren E. Burger, to argue that perspective. Cassell was then a professor at the University of Utah law school; he was later appointed to, and subsequently resigned from, a federal district court judgeship in that state.

Background

In ''Miranda v. Arizona'', the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by police may not be admitted in court unless the suspect first had certain warnings read to them beforehand. By now, these warnings are familiar to most Americans: that the suspect has the right to remain silent during the interrogation, that anything they say to the police may be used against them in a court of law, that they have the right to legal counsel, and that if they cannot afford legal counsel a lawyer will be provided for them.

In 1968, two years after the ''Miranda'' decision, Congress passed a law that purported to overrule it as part of the Omnibus Crime Control and Safe Streets Act of 1968. This statute, 18 U.S.C. § 3501, directed federal trial judges to admit statements of criminal defendants if they were made voluntarily, without regard to whether they had received the ''Miranda'' warnings. Under § 3501, voluntariness depended on such things as (1) the time between arrest and arraignment, (2) whether the defendant knew the crime for which they had been arrested, (3) whether they had been told that they did not have to talk to the police and that any statement could be used against them, (4) whether the defendant knew prior to questioning that they had the right to the assistance of counsel, and (5) whether they actually had the assistance of counsel during questioning. However, the "presence or absence of any of" these factors "need not be conclusive on the issue of voluntariness of the confession." Because § 3501 was an act of Congress, it applied only to federal criminal proceedings and criminal proceedings in the District of Columbia.

Charles Dickerson had been arrested for bank robbery and for using a firearm during a crime of violence, both federal crimes. He moved to suppress statements he made to the FBI because he had not received the ''Miranda'' warnings before he spoke to the FBI. The district court suppressed the statements, and so the government appealed. The Fourth Circuit reversed the district court, reasoning that § 3501 had supplanted the requirement that the police give the ''Miranda'' warnings because ''Miranda'' was not a constitutional requirement and therefore Congress could overrule that decision by legislation. The Supreme Court then agreed to hear the case.

Opinion of the Court

Chief Justice Rehnquist wrote the majority opinion, and began by briefly describing the historical backdrop against which the ''Miranda'' ruling had emerged. A suspect's confession had always been inadmissible if it had been the result of coercion or otherwise given involuntarily. This was true in England, from where American law inherited that rule.

However, as time went on, the Supreme Court recognized that the Fifth Amendment was an independent source of protection for statements made by criminal defendants in the course of police interrogation. "In ''Miranda'', we noted that the advent of modern custodial police interrogation brought with it an increased concern about confessions obtained by coercion." Custodial police interrogation by its very nature "isolates and pressures the individual" so that he might eventually be worn down and confess to crimes he did not commit in order to end the ordeal. In ''Miranda'', the Court had adopted the now-famous four warnings to protect against this particular evil.

Congress, in response, enacted § 3501. That statute clearly was designed to overrule ''Miranda'' because it expressly focused solely on voluntariness of the confession as a touchstone for admissibility. Did Congress have the authority to pass such a law? On the one hand, the Court's power to craft nonconstitutional supervisory rules over the federal courts exists only in the absence of a specific statute passed by Congress. However, if on the other hand the ''Miranda'' rule was constitutional, Congress could not overrule it, because the Court alone is the final arbiter of what the Constitution requires. As evidence of the fact that the ''Miranda'' rule was constitutional in nature, the Court pointed out that many of its subsequent decisions applying and limiting the requirement arose in decisions from state courts, over which the Court lacked the power to impose supervisory nonconstitutional rules. Furthermore, although the Court had previously invited legislative involvement in the effort to devise prophylactic measures for protecting criminal defendants against overbearing tactics of the police, it had consistently held that these measures must not take away from the protections ''Miranda'' had afforded.

Finally, 34 years after the original decision, the Court was loath to overrule ''Miranda''. Typically, the Court overrules constitutional decisions only when their doctrinal underpinnings have eroded. The Court felt that this was not the case in ''Miranda''. "If anything, our subsequent cases have reduced the impact of the ''Miranda'' rule on legitimate law enforcement while reaffirming the decision's core ruling that unwarned statements may not be used as evidence in the prosecution's case in chief." The ''Miranda'' rule did not displace the voluntariness inquiry.

Dissent

Justice Scalia, joined by Justice Thomas, disagreed with the majority's decision not to overrule ''Miranda''. He disputed the notion that ''Miranda'' was a constitutional rule, pointing to several cases in which the Court had declined to exclude evidence despite the absence of warnings.

Justice Scalia described the majority's decision as an unprincipled compromise between justices who believed ''Miranda'' was a constitutional requirement and those who disagreed. He noted that the majority did not state outright that the Miranda warning is a constitutional requirement, but merely that it is "constitutionally based." Justice Scalia further criticized the majority for implying that Congress has no power to override judicially imposed safeguards of constitutional rights ('' Marbury v. Madison'' (1803) having settled that Congress may not override judicial ''interpretations'' of the Constitution).

References

External links

* {{caselaw source
, case=''Dickerson v. United States'', {{ussc, 530, 428, 2000, el=no
, cornell =https://www.law.cornell.edu/supct/html/99-5525.ZS.html
, courtlistener =https://www.courtlistener.com/opinion/118380/dickerson-v-united-states/
, findlaw =
, googlescholar = https://scholar.google.com/scholar_case?case=12360733536043994298
, justia =https://supreme.justia.com/cases/federal/us/530/428/
, loc =http://cdn.loc.gov/service/ll/usrep/usrep530/usrep530428/usrep530428.pdf
, oyez =https://www.oyez.org/cases/1999/99-5525

Brief of the Criminal Justice Legal Foundation





2000 in United States case law
Miranda warning case law
United States Supreme Court cases
United States Supreme Court cases of the Rehnquist Court