Rhode Island v. Innis 446 U.S. 291, 100 S. Ct. 1682, 64 L. Ed.2d 297 (1980)
Innis was arrested on
suspicion of robbing and killing a cab driver. He was given two Miranda
Warnings at the time of his arrest and
he asked to see a lawyer. The police put Innis in the back of a police
car and drove him to the police station.
En route, the policemen began
talking among themselves about how the murder weapon was missing and how
tragic it would be if some kids found it. Innis interrupted the
conversation and told them where to find the weapon.
Back at the scene, Innis was
given a third Miranda Warning but
led the police to the weapon anyway.
At trial, the prosecutor
attempted to introduce the weapon and Innis' knowledge of its whereabouts.
The Trial Judge allowed the evidence to be admitted over Innis'
Innis argued that he had
been interrogated without assistance of counsel, since he had asked to
see a lawyer and had not been given one.
The Trial Court found Innis
guilty of robbery and murder. He appealed.
The Rhode Island Supreme Court
overturned the conviction. The prosecutor appealed.
The Rhode Island Supreme
Court found that the police had interrogated Innis in the police car, and had used subtle
coercion methods to trick him into confessing.
The US Supreme Court reversed
and upheld the conviction.
The US Supreme Court agreed
that police interrogations can include more that simply direct
questioning in an interrogation room.
However, The Court found
that not all statements obtained by police after a person has been
arrested are to be considered the product of interrogations.
In order to count as an
interrogation, there must be a measure of compulsion above and beyond
that inherent in custody itself.
That means "any words
or action on the part of the police that they should know are reasonably
likely to elicit an incriminating response from the suspect."
The Court looked at the
facts of the case and found that there was no reason for the police to
believe that their conversation would get Innis to confess to knowing
where the murder weapon was.
In a dissent it was argued
that the police conversation about dead children was clearly designed to
guilt Innis into confessing, therefore it met the objective standard for
How was the policeman's
statement fundamentally different from just asking Innis directly where
the shotgun was so that they could protect children from finding it?
Basically, the Court said that
it only counts as an interrogation if the suspect's response was the
product of words or actions on the part of the police that they should
have known were reasonably likely to elicit the incriminating response.
This is an objective
standard. It doesn't matter why the particular policeman said what he
said. It is only what a reasonable policeman would think about what was
It wasn't noted in this case,
but the Court could have probably also justified the questioning as being
admissible under the Public Safety Exception.