Innis 446 US Court Case Study

Rhode Island v. Innis 446 U.S. 291 (1980)
FACTS:
Substantive Facts: Respondent was arrested on the night of January 12, 1975 for the robbery of Providence cab driver John Mulvaney, which lead to his murder. Mulvaney was shot in the head with a sawed-off shotgun, however no weapon was found present on the respondent at the time of his arrest. Upon the respondents’ arrest, respondent was informed of his Miranda rights by three police officers, to which he explained he understood those rights and wanted to speak with a lawyer. Officers then placed the respondent in the rear of a squad car containing the three aforementioned officers, one of which was seated in the rear with the defendant. Once en route to the police station, the officers began
conversing about what a tragedy it would be if someone, namely a child who attended the nearby special education school, were to stumble upon the unaccounted weapon and harm themselves with it. Respondent then interrupted the officers’ conversation to divulge the location of the shotgun he had used in the crime in order to avoid the aforementioned accident from ever occurring. Procedural Facts: Pre-trial, respondent moved to suppress the shotgun and statements he made regarding it. The Trial Court of Rhode Island denied the motion to suppress and allowed the shotgun and the statements to be presented. Respondent appealed his conviction of guilty on all counts, and the Rhode Island Supreme Court set aside the respondents’ conviction in addition to remanding the case for further proceedings not inconsistent with the court’s opinion and concluded Innis was entitled to a new trial.

ISSUE: Does the conversation between the officers in front of the respondent constitute an ‘interrogation’ in violation of the respondent’s undisputed rights defined in the Miranda opinion?

HOLDING: No. The conversation was found to not be an interrogation, and therefore the respondent’s Fifth Amendment rights as stated in the U.S. Constitution were not violated.

REASONING: A “custodial interrogation” is described in this case as “questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way”.
As further reiterated, “Confessions remain a proper element in law enforcement. Any statement given freely and voluntarily without any compelling influences is, of course, admissible in evidence.” Furthermore, the Fifth Amendment does not bar voluntary statements by definition. The Fifth Amendment explicitly states “No person shall…be compelled in any criminal case to be a witness against himself”. The issue here was whether or not the conversation was in fact an interrogation based on the subdivision called the “functional equivalent” of questioning, described as ‘any words or actions on the part of the police that the police should know are reasonably likely to elicit an incriminating response from the suspect’. The court found that the conversation did not fall within the Miranda meaning of “interrogation” because it was concluded as being nothing more than a dialogue between the two officers, which invited no response from the respondent, and was clearly not a questioning initiated by officers. Furthermore, the conversation also was found not to fall under the description of “functional equivalent” because the few ‘offhand’ remarks that the officers made to one another in no way subjected the respondent to elicit a statement of admission, nor were the officers’ actions subjecting the respondent. Consequently, the respondent was found to have given a confession in a voluntary manner and that his Fifth Amendment rights were not deprived because he was not compelled or forced in any way to
self-incriminate.

DISSENTING OPINION: Justice Marshall discussed the nature of the arrest and argued that although he did agree with the definition of “interrogation” under the meaning of Miranda V. Arizona, that the environment and position that the respondent was put in fits the “functional equivalent” to interrogation. Mentioning that Innis was arrested at 4:30 AM, handcuffed, had his rights barked at him multiple times, and was then placed in the backseat of a car with three other officers was horrifying enough, but almost immediately after getting into the vehicle, the officers began discussing the search for the gun. The officers used what is described as a “classic interrogation technique” by appealing the respondent to confess for the sake of others, playing on his emotions by talking to one another about the thought of an innocent, handicapped child hurting herself with the unaccounted weapon. Simply because the officers were said to be speaking with one another they were off the hook, but Marshall thinks this is ludicrous. He notes that the officers were sitting in close quarters with a handcuffed suspect whom could clearly hear them speak about a subject that would inarguably appeal to a person’s conscience. They knew the respondent would hear them and that any reasonable person would likely admit to their wrongdoings for the sake of others. He stands firm that the officers should be responsible for knowingly putting unlawful pressure on the respondent.