Cjad

Facts:

Dickerson was indicted for bank robbery, conspiracy to commit bank robbery, and using a firearm in the commission of a crime of violence, all in violation of the applicable provisions of Title 18 of the United States Code. Subsequent to the decision in Miranda v. Arizona, Congress passed a law that purported to allow evidence to be admitted against defendants who had no received proper Miranda, and granted his motion to suppress. The United States Attorney on behalf of the federal government took an interlocutory appeal to the United States Court of Appeals for the Fourth Circuit. The Court of Appeals reversed the District Court even though it concluded that the Miranda and to allow a defendant’s statements voluntarily made to be admissible in court against a defendant. The United States Supreme Court granted certiorari. Issue:

Was the Supreme Court decision in Miranda v. Arizona, mandating specific warnings to persons who are questioned while in custody, required by the Constitution? Decision of the Court:

The Supreme Court’s decision in Miranda, being a constitutional decision of the Supreme Court, may not , in effect, be overruled by an Act of Congress and a defendant who has not been properly warned may not have the statement used against them in a court of law. Reasoning of the Court:

The Supreme Court first determined that it was the clear intention of the Congress to overrule the Miranda v. Arizona decision by instructing courts to consider only the totality of the circumstances involving voluntariness of a statement or confession in determining whether is should be admitted against a defendant. The Supreme Court noted that it possesses supervisory authority over the federal courts to prescribe binding rules of evidence and procedure. It emphasized that while Congress has ultimate authority to modify or set aside any such rules that are not constitutionally required or of constitutional dimension, the Congress may not supersede the Court’s decisions interpreting and applying the Constitution. The Court noted that it does not have a general supervisory role over state courts and could not have applied a rule as was devised in Miranda v. Arizona unless such a rule was of constitutional dimension and required by the Constitution of the United States. The Court held that Miranda announced a constitutional rule, demonstrated by the fact that the Miranda case was replete with statements indicating that the majority thought it was announcing a constitutional dimension in Miranda.

The Supreme Court rejected arguments to overrule Miranda v. Arizona, noting that in cases of constitutional dimension, stare decisis weighs heavily against overruling Miranda at this time. Citations to Support Judgment: Carlisle v. United States, 517 U.S. 416 (1996)Palermo v. United States, 360 U.S. 343 (1959)City of Boerne v. Flores, 521 U.S. 597 (1997)Stansbury v. California, 511 U.S. 318 (1994) Rule of Law:

Congress cannot reverse a decision of the Supreme Court where the result of a court case has been mandated by the Constitution of the United States. Where the Constitution requires that arrestees be properly warned prior to interrogation, and where the warnings are not properly given, the evidence must be excluded despite the clear intent of Congress to allow the evidence to be admissible in federal criminal trials. Dissent:

Justices Scalia and Thomas dissented. The dissenting judges believed that the decision was erroneous because Miranda was not originally a decision carrying constitutional dimension. The two justices noted that to those who understand the judicial process, the Dickerson decision will be obvious that it was not merely a reaffirmation of Miranda, but a radical revision of the most significant element of Miranda, and gives the Miranda rationale a permanent place in our jurisprudence that will not likely ever be overruled.

Citations: to Support Judgment: Carlisle v. United States, 517 U.S. 416 (1996)Palermo v. United States, 360 U.S. 343 (1959)City of Boerne v. Flores, 521 U.S. 597 (1997)Stansbury v. California, 511 U.S. 318 (1994) Rule of Law: Congress cannot reverse a decision of the Supreme Court where the result of a court case has been mandated by the Constitution of the United States. Where the Constitution requires that arrestees be properly warned prior to interrogation, and where the warnings are not properly given, the evidence must be excluded despite the clear intent of Congress to allow the evidence to be admissible in federal criminal trials. Dissent: Justices Scalia and Thomas dissented. The dissenting judges believed that the decision was erroneous because Miranda was not originally a decision carrying constitutional dimension. The two justices noted that to those who understand the judicial process, the Dickerson decision will be obvious that it was not merely a reaffirmation of Miranda, but a radical revision of the most significant element of Miranda, and gives the Miranda rationale a permanent place in our jurisprudence that will not likely ever be overruled.