Brief Fact Summary. The petitioner, Charles Thomas Dickerson (the “petitioner”), made a statement regarding a bank robbery to the Federal Bureau of Investigations (“FBI”) without receiving his Miranda rights. A federal law was in place that allowed the admission of statements if they were voluntarily made.
Synopsis of Rule of Law. Congress cannot overrule the Miranda v. Arizona decision because it was a decision based on the United States Constitution (“Constitution”) rather than simply court-made law.
Congress retains the ultimate authority to modify or set aside any judicially created rules of evidence and procedure that are not required by the Constitution.View Full Point of Law
Issue. The issue is whether Congress can overrule the Fourth and Fourteenth Amendment constitutional protections outlined in Miranda.
Held. The protections outlined in Miranda, are protections mandated by the Constitution. Therefore Congress, through a federal law, can not overrule Miranda. The United States Supreme Court is not willing to overrule Miranda, and therefore the statements should be suppressed.
Dissent. The dissent believes that the Congressional law is not unconstitutional, and that Miranda should not be interpreted as a constitutional decision.
Discussion. The decision clearly affirms Miranda, elevating it to a status of a constitutional requirement that can not be overturned by simple Congressional law.