Dickerson V. United States - Background

Background

In Miranda v. Arizona, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by police may not be admitted in court unless the suspect first had certain warnings read to him beforehand. By now, these warnings are familiar to most Americans—the suspect has the right to remain silent during the interrogation, that anything he says to the police may be used against him in a court of law, that he has the right to legal counsel, and that if he cannot afford legal counsel a lawyer will be provided for him.

In 1968, two years after the Miranda decision, Congress passed a law that purported to overrule it. This statute, 18 U.S.C. § 3501, directed federal trial judges to admit statements of criminal defendants if they were made voluntarily, without regard to whether he had received the Miranda warnings. Under § 3501, voluntariness depended on such things as (1) the time between arrest and arraignment, (2) whether the defendant knew the crime for which he had been arrested, (3) whether he had been told that he did not have to talk to the police and that any statement could be used against him, (4) whether the defendant knew prior to questioning that he had the right to the assistance of counsel, and (5) whether he actually had the assistance of counsel during questioning. But the "presence or absence of any of" these factors "need not be conclusive on the issue of voluntariness of the confession." Because § 3501 was an act of Congress, it applied only to federal criminal proceedings and criminal proceedings in the District of Columbia.

Dickerson had been arrested for bank robbery and for using a firearm during a crime of violence, both federal crimes. He moved to suppress statements he made to the FBI because he had not received the Miranda warnings before he spoke to the FBI. The district court suppressed the statements, and so the government appealed. The Fourth Circuit reversed the district court, reasoning that § 3501 had supplanted the requirement that the police give the Miranda warnings because Miranda was not a constitutional requirement and therefore Congress could overrule that decision by legislation. The Supreme Court then agreed to hear the case.