Dickerson v. United States 530 U.S. 428, 120 S.Ct. 2326, 147 L.Ed.2d 405 (2000)
After the decision in Miranda
v. Arizona (384 U.S. 486 (1966)) led
to confessions being held inadmissible because of the lack of a Miranda
Warning, there was a perception that the guilty were being let
off the hook. In response, Congress passed 18 U.S.C. §3501, which allowed judges to admit statements of
criminal defendants if they were made voluntarily.
Under §3501 whether he had received the Miranda
Warning was just one factor in a totality of the circumstances
That's a throwback to the
pre-Miranda rule of voluntariness.
See Ashcraft v.
Tennessee (322 U.S. 143 (1944)).
Dickerson was arrested for
bank robbery. He made some incriminating statements to the FBI before he
received a Miranda Warning.
At trial, the Trial Judge
suppressed the statements. The prosecutor appealed.
The Appellate Court reversed.
The Appellate Court found
that §3501 had supplanted the
requirement that police give Miranda Warnings.
The Appellate Court found
that the Miranda Warning is just a
procedural safeguard and not a Constitutional requirement, so Congress
has the authority to overrule it with legislation.
The US Supreme Court reversed
and found Dickerson's statement inadmissible.
The US Supreme Court found
that the decision in Miranda was
a Constitutional interpretation of the 5th Amendmentright against self-incrimination.
As such, Congress does not have the authority to overrule it.
See Marbury v. Madison
In a circular argument, the
Court noted that State courts routinely apply the ruling in Miranda to State cases. Since only Constitutional
issues apply to the States, Miranda must stem from a Constitutional issue.
If it wasn't, the States
would just be ignoring it, right?
The Court found that even
though they had developed some exceptions to the Miranda Warning (like the public safety exception) the 'core holding' is still an immutable
The Court found that they'd
been applying Miranda for many
years, and that it had become a standard part of police practice and
"our Nation's culture," and that it shouldn't be superceded by §3501.
The Court noted that §3501 is more difficult to apply and lacks
In a dissent, it was pointed
out that the majority never explicitly says that failure to give a Miranda
Warning is a Constitutional violation.
Therefore, you can't say that §3501 is in violation of the
The Constitution only
prevents compelled confessions,
not "foolish" ones. Therefore the dissent felt that the Miranda
Warning is not a Constitutional
requirement. §3501 makes any voluntary (non-compelled)
confession admissible and thus meets the requirements of the 5th
Amendment. Miranda extends Constitutional protections to
confessions that are not compelled. The dissent felt that was