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’ objection.
    • 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 than 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 an interrogation.
    • 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 said.
  • 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.