Dickerson v. United States, 530 U.S. 428; 120 S. Ct. 2326; 147 L. Ed. 2d 405 (2000)
Facts—In 1968 Congress adopted legislation designed to modify Miranda v. Arizona (1966) so as to accept voluntary confessions even in cases where police officers had not read defendants their rights. On the basis of Miranda, a U.S. District Court suppressed voluntary statements Dickerson made to the FBI in the absence of law enforcement warnings, but the U.S. Fourth Circuit Court decided that the 1968 law had been met and that Miranda was not a constitutional rule.
Questions—(a) Are solicited voluntary confessions admissible in the absence of Miranda warnings? (b) Was Miranda a constitutional ruling?
Decisions—(a) No; (b) Yes.
Reasons—C.J. Rehnquist (7–2). Prior to Miranda, the Court used the voluntariness test for confessions, relying chiefly on the Fifth and Fourteenth Amendments, but Miranda added more “concrete constitutional guidelines,” which the 1968 legislation attempted to circumvent. The Supreme Court exercises supervisory authority over other federal courts, which Congress can alter through legislation, but “Congress may not legislatively supersede our decisions interpreting and applying the Constitution.” Miranda was more than an exercise of the Supreme Court’s supervisory power as witnessed by the fact that the decision has also been applied to state court proceedings over which the Court does not have such supervisory authority. The Miranda decision “is replete with statements indicating that the majority thought it was a constitutional rule.” The Court has subsequently made some exceptions to the Miranda decision, but that does not establish that Miranda “is not a constitutional rule” but “that no constitutional rule is immutable.” Stare decisis weighs heavily against overruling Miranda. The rules prescribed in that case have “become embedded in routine police practice to the point where the warnings have become part of our national culture.” The Court thus reaffirmed Miranda as a constitutional rule that may not be evaded through congressional legislation.
J. Scalia argued that Miranda and its progeny did not merely “apply the Constitution” but sought “to expand it,” and he believed such an expansion was unwise and undemocratic. He thought it “preposterous” to read Miranda as a standard of what the Constitution required. It was not aimed, like the Fifth Amendment, at “compelled” confessions but at “foolish” ones. It was a prophylactic rule that went far beyond constitutional requirements. The subsequent exceptions to Miranda did undermine its alleged constitutional foundation. Because Miranda required the invalidation of legislation that did not violate the Constitution, it should be abandoned. The “supposed workability” of the Miranda rules are not as clear as they seem; they create as many questions as they resolve. The Court’s continuing adherence to Miranda is a sign of “judicial arrogance.”
