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 test.
    • 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. Dickerson appealed.
    • 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 Amendment right 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 Constitutional rule.
    • 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years, and that it had become a standard part of police practice and “our Nation’s culture,” and that it shouldn’t be superceded by §3501.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 consistency.
  • 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 Constitution.
    • 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 overreaching.