Resource: The Dickerson Case

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Critics of the 1966 Miranda v. Arizona decision had their chance to see it reversed in 2000. With Miranda, the Supreme Court had established police procedures to safeguard people’s right against self-incrimination when they are interrogated in police custody.

While clear on the rights of suspects held by the police, the Court was much less clear about exactly how police must ensure suspects know their rights. The Court acknowledged that the Constitution does not require any particular method or solution for notifying accused people of their right to silence and to an attorney. In fact, in writing for the majority, Chief Justice Earl Warren encouraged Congress and the states to exercise “their creative rule-making capacities” to search for “effective ways of protecting the rights of individuals while promoting efficient enforcement of our criminal laws.”

Two years after the Miranda decision, Congress accepted the Court’s invitation to create its own police rules to enforce Miranda. It passed the Omnibus Crime Control Act of 1968. Section 3501 of the Act said that courts should evaluate many different factors when they determine if confessions were issued voluntarily and whether they were admissible --- not just whether suspects were issued proper Miranda warnings. In other words, if there was other evidence that the confessions were made voluntarily and that a suspect knew he was entitled to a lawyer, then those statements could be used in court regardless of whether police issued proper Miranda warnings.

The constitutionality of that law was the main question in the case of Dickerson v. United States, 2000. In that case, a defendant confessed to being a driver of a getaway car in several bank robberies. The District Court suppressed the confession on the grounds that he had not been properly Mirandized. An appeals court, citing the Omnibus Crime Control Act of 1968, concluded that the confession was admissible even without proper Miranda warnings because there was other sufficient evidence that it had been made voluntarily. The court reminded everyone that when the Supreme Court issued Miranda, it specifically referred to the Congress's authority to create its own rules and procedures related to advising suspects of their rights.

The Supreme Court disagreed. It ruled in favor of Dickerson and reaffirmed the Miranda decision saying it was “a constitutional decision of the Court and it may not be overruled by an Act of Congress.” The opinion was written by Chief Justice Rehnquist himself, one of the jurists who had been most critical of Miranda when it was issued. In addition to asserting the Court’s right to determine what is constitutional (not the Congress’s right), he stressed “the principles of stare decisis weigh heavily against overruling it now… We do not think there is such a justification for overruling Miranda. Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture.”

--adapted from the Web site Landmark Supreme Court Cases

Print Questions for Discussion

• Why did Chief Justice Rehnquist, who had always been critical of the Miranda decision, uphold that decision in the Dickerson case?
• What does Chief Justice Roberts mean when he says that he'd be surprised if Justice Rehnquist's view on a number of areas didn't change when he moved from as associate justice to being the chief justice? What does Roberts say about the responsibilities of the Chief Justice?
• What justification does the Court provide for affirming Miranda?