Brief Fact Summary. The defendants offered incriminating evidence during police interrogations without prior notification of their rights under the Fifth Amendment of the United States Constitution (the “Constitution”).
Synopsis of Rule of Law. Government authorities need to inform individuals of their Fifth Amendment constitutional rights prior to an interrogation following an arrest.
The second Defendant, Michael Vignera (“Mr. Vignera”), was arrested for robbery. Mr. Vignera orally admitted to the robbery to the first officer after the arrest, and he was held in detention for eight hours before he made an admission to an assistant district attorney. There was no evidence that he was notified of his Fifth Amendment constitutional rights.
The third Defendant, Carl Calvin Westover (“Mr. Westover”), was arrested for two robberies. Mr. Westover was questioned over fourteen hours by local police, and then was handed to Federal Bureau of Investigation (“FBI”) agents, who were able to get signed confessions from Mr. Westover. The authorities did not notify Mr. Westover of his Fifth Amendment constitutional rights.
The fourth Defendant, Roy Allen Stewart (“Mr. Stewart”), was arrested, along with members of his family (although there was no evidence of any wrongdoing by his family) for a series of purse snatches. There was no evidence that Mr. Stewart was notified of his rights. After nine interrogations, Mr. Stewart admitted to the crimes.
Issue. Whether the government is required to notify the arrested defendants of their Fifth Amendment constitutional rights against self-incrimination before they interrogate the defendants?
Held. The government needs to notify arrested individuals of their Fifth Amendment constitutional rights, specifically: their right to remain silent; an explanation that anything they say could be used against them in court; their right to counsel; and their right to have counsel appointed to represent them if necessary. Without this notification, anything admitted by an arrestee in an interrogation will not be admissible in court.
Dissent. Justice Tom Clark (“J. Clark”) argued that the Due Process Clauses of the Fifth and Fourteenth Amendments of the Constitution would apply to interrogations. There is not enough evidence to demonstrate a need to apply a new rule as the majority finds here.
The second dissent written by Justice John Harlan (“J. Harlan”) also argues that the Due Process Clauses should apply. J. Harlan further argues that the Fifth Amendment rule against self-incrimination was never intended to forbid any and all pressures against self-incrimination.
Justice Byron White (“J. White”) argued that there is no historical support for broadening the Fifth Amendment of the Constitution to include the rights that the majority extends in their decision. The majority is making new law with their holding.
Discussion. The majority notes that once an individual chooses to remain silent or asks to first see an attorney, any interrogation should cease. Further, the individual has the right to stop the interrogation at any time, and the government will not be allowed to argue for an exception to the notification rule.