Dickerson V. United States - Decision

Decision

Chief Justice Rehnquist wrote the majority opinion, and began by briefly describing the historical backdrop against which the Miranda ruling had emerged. A suspect's confession had always been inadmissible if it had been the result of coercion, or otherwise given involuntarily. This was true in England, and American law inherited that rule from England.

However, as time went on, the Supreme Court recognized that the Fifth Amendment was an independent source of protection for statements made by criminal defendants in the course of police interrogation. "In Miranda, we noted that the advent of modern custodial police interrogation brought with it an increased concern about confessions obtained by coercion." Custodial police interrogation by its very nature "isolates and pressures the individual" so that he might eventually be worn down and confess to crimes he did not commit in order to end the ordeal. In Miranda, the Court had adopted the now-famous four warnings to protect against this particular evil.

Congress, in response, enacted § 3501. That statute clearly was designed to overrule Miranda because it expressly focused solely on voluntariness of the confession as a touchstone for admissibility. Did Congress have the authority to pass such a law? On the one hand, the Court's power to craft nonconstitutional supervisory rules over the federal courts exists only in the absence of a specific statute passed by Congress. But if on the other hand the Miranda rule was constitutional, Congress could not overrule it, because the Court alone is the final arbiter of what the Constitution requires. As evidence of the fact that the Miranda rule was constitutional in nature, the Court pointed out that many of its subsequent decisions applying and limiting the requirement arose in decisions from state courts, over which the Court lacked the power to impose supervisory nonconstitutional rules. Furthermore, although the Court had previously invited legislative involvement in the effort to devise prophylactic measures for protecting criminal defendants against overbearing tactics of the police, it had consistently held that these measures must not take away from the protections Miranda had afforded.

Finally, 34 years after the original decision, the Court was loath to overrule Miranda. Typically, the Court overrules constitutional decisions only when their doctrinal underpinnings have eroded. The Court felt that this was not the case in Miranda. "If anything, our subsequent cases have reduced the impact of the Miranda rule on legitimate law enforcement while reaffirming the decision's core ruling that unwarned statements may not be used as evidence in the prosecution's case in chief." The Miranda rule did not displace the voluntariness inquiry.