Miranda v. Arizona concerned itself with the conviction of Ernest Arturo Miranda, petitioner and defendant, who had been convicted of two crimes – rape and kidnapping – sentences on each count of 20 to 30 years to run concurrently. In a separate case, the defendant had been convicted of the crime of robbery, committed as a separate act.
The issue before the United States Supreme Court was the admission into evidence of the defendant’s statements, over the objection of trial counsel.
In June of 1963, the trial court allowed the confession into evidence. In April 1965, the Arizona Supreme Court affirmed the conviction. The Supreme Court granted review. The defendant was a 22 year old hispanic who had been arrested in March 13, 1963, taken to a police station by Officers Young and Cooley, placed in a line-up, where he was identified by the victim in the rape case. He was then taken into an interview booth – Interrogation Room #2 – at approximately 11:30 AM that morning. By 1:30 pm the police had obtained a confession.
He denied his guilty at the commencement of the interrogation. By 1:30 he had confessed. At no point during his interrogation nor prior to his oral confession was Mr. Miranda advised of his right to counsel or his right to remain silent. At the conclusion of his interview, he was then asked to sign a confession. He agreed. He was handed a type-written form which said “I, Ernest A. Miranda do hereby swear that I make this statement voluntarily and of my own free will, with no threats, coercion, or promises of immunity and with full knowledge of my legal rights understanding any statement I make may be used against me.” This statement was also read to him by the officers. Mr. Miranda confessed in his own handwriting.
The issue was whether the confession had been voluntarily given, in light of the officers’ failure to give Miranda appropriate warnings. The Supreme Court held in a 5-4 decision that before the police conduct an in-custody interrogation, they must advise the defendant of his rights – “Miranda Warnings” – absent an exception. One exception is an exigent circumstances exception where the questioning is required to avert some immediate threat or harm to other people.
The Miranda case was decided in the context of a rich history of police abuse where purportedly voluntary confessions had been beaten or coerced out of defendants.
Miranda closely followed Escobedo v. Illinois, a 1964 Supreme Court case involved Danny Escobedo, a Chicago man accused of killing his brother-in-law. On the evening of January 19, 1960, the defendant’s brother-in-law was shot dead in a garage behind his home. This happened about midnight. The defendant, a 22-year-old young man, was arrested in early morning hours. He was taken to the police station for approximately 14 or 15 hours where he was questioned until his attorney – an attorney he had retained for a private lawsuit some 6 months earlier – showed up at the station with a Writ of Habeas Corpus and got Escobedo released.
On January 30, 1960, police again arrested Escobedo and urged him to confess. This time, he was taken by police to police headquarters as 12th and State. During the ride, police officers claimed they had evidence that linked Escobedo to the killing. At about 9:30 (an hour and a half later), Escobedo (and his girlfriend who had also been arrested) arrived at the police station.
Escobedo requested to see his attorney.
His attorney – who had probably been informed by friends or family members about Escobedo’s arrest – also arrived shortly after at the police station. He also requested to see his client, Escobedo. Police refused him access to his client, and refused Escobedo permission to consult with his attorney.
The attorney was not content with this refusal, and so he went to just outside the room where Escobedo was being questioned, where Escobedo overheard his attorney outside the room requesting to see him. Escobedo again asked to talk to his attorney, and was again denied permission.
The Supreme Court held in a 5-4 decision that the failure of the police to afford Escobedo an attorney therefore made his confession inadmissible in court.