Dickerson v. United States
Decided June 26, 2000, 530 U.S. 428


A constitutional decision of the US Supreme Court may not be in effect overruled by an Act of Congress.

I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?

I. ISSUES:

A. Issues Discussed:
Miranda warnings, United States Supreme Court's authority

B. Legal Question Presented:

Can a Supreme Court constitutional decision, such as Miranda v. Arizona, which governs the admissibility of statements made during custodial interrogation, be overruled by an Act of Congress?

II. CASE SUMMARY:

A. Background:

"In the wake of Miranda v. Arizona, in which the Court held that certain warnings must be given before a suspect's statement made during custodial interrogation could be admitted in evidence, Congress enacted 18 U. S. C. §3501, which in essence makes the admissibility of such statements turn solely on whether they were made voluntarily.

Petitioner, under indictment for bank robbery and related federal crimes, moved to suppress a statement he had made to the Federal Bureau of Investigation, on the ground he had not received 'Miranda warnings' before being interrogated. The District Court granted his motion, and the Government took an interlocutory appeal.

In reversing, the Fourth Circuit acknowledged that petitioner had not received Miranda warnings, but held that §3501 was satisfied because his statement was voluntary. It concluded that Miranda was not a constitutional holding, and that, therefore, Congress could by statute have the final say on the admissibility question."

On certiorari, the US Supreme Court reversed the judgment of the United States Court of Appeals for the Fourth Circuit.

B. Counsel of Record:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
C. The Arguments:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavailable Unavailable
III. AMICI CURIAE:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
James W. Hundley, by appointment of the Court, 528 U. S. 1072, argued the cause for petitioner. With him on the briefs were Carter G. Phillips, Jeffrey T. Green, and Kurt H. Jacobs. Solicitor General Waxman argued the cause for the United States. With him on the briefs were Attorney General Reno, Assistant Attorney General Robinson, Deputy Solicitor General Dreeben, James A. Feldman, and Lisa S. Blatt.

Briefs of amici curiae urging reversal were filed for the American Civil Liberties Union by Jonathan L. Abram, Audrey J. Anderson, Steven R. Shapiro, Vivian Berger, Susan N. Herman, and Stephen Schulhofer; for the House Democratic Leadership by Charles Tiefer and Jonathan W. Cuneo; for the National Association of Criminal Defense Lawyers et al. by Paul M. Smith, Deanne E. Maynard, Lisa B. Kemler, and John T. Philipsborn; for the National Legal Aid and Defender Association by Charles D. Weisselberg and Michelle Falkoff; for the Rutherford Institute by James Joseph Lynch, Jr., and John W. Whitehead; for Griffin B. Bell by Robert S. Litt, John A. Freedman, and Daniel C. Richman; and for Benjamin R. Civiletti by Mr. Civiletti, pro se, Kenneth C. Bass III, and John F. Cooney.

Paul G. Cassell, by invitation of the Court, 528 U. S. 1045, argued the cause as amicus curiae urging affirmance. With him on the brief were Daniel J. Popeo and Paul D. Kamenar.

Briefs of amici curiae urging affirmance were filed for the State of South Carolina et al. by Charles M. Condon, Attorney General of South Carolina, Treva Ashworth, Deputy Attorney General, Kenneth P. Wood-ington, Senior Assistant Attorney General, and Travey Colton Green, Assistant Attorney General; for the Maricopa County Attorney's Office by Theodore B. Olson, Douglas R. Cox, and Miguel A. Estrada; for Arizona Voices for Victims et al. by Douglas Beloof; for the Bipartisan Legal Advisory Group of the United States House of Representatives by Geraldine R. Gennet, Kerry W. Kircher, and Michael L. Stern; for the Center for the Community Interest et al. by Daniel P. Collins, Kristin Linsley Myles, and Kelly M. Klaus; for the Center for the Original Intent of the Constitution by Michael P. Farris; for Citizens for Law and Order et al. by Theodore M. Cooperstein; for the Criminal Justice Legal Foundation by Kent S. Scheidegger, Charles L. Hobson, and Edwin Meese III; for the Federal Bureau of Investigation Agents Association by Robert F. Hoyt; for the Fraternal Order of Police by Patrick F. Philbin and Thomas T. Rutherford; for the National Association of Police Organizations et al. by Stephen R. McSpadden, Robert J. Cynkar, and Margaret A. Ryan; for the National District Attorneys Association et al. by Lynne Abraham, Ronald Eisenberg, Jeffrey C. Sullivan, John M. Tyson, Jr., Grover Trask, Christine A. Cooke, John B. Dangler, and Richard E. Trodden; for Former Attorneys General of the United States William P. Barr and Edwin Meese III by Andrew G. McBride; for Senator Orrin G. Hatch et al. by Senator Hatch, pro se; and for Manning & Marder, Kass, Ellrod, Ramirez by Davis J. Wilson.

IV. THE SUPREME COURT'S DECISION:

The Supreme Court held that:

"Miranda and its progeny in this Court govern the admissibility of statements made during custodial interrogation in both state and federal courts.

Miranda, being a constitutional decision of this Court, may not be in effect overruled by an Act of Congress. Given §3501's express designation of voluntariness as the touchstone of admissibility, its omission of any warning requirement, and its instruction for trial courts to consider the totality of the circumstances surrounding the giving of the confession, this Court agrees with the Fourth Circuit that Congress intended §3501 to overrule Miranda. The law is clear as to whether Congress has constitutional authority to do so. This Court has supervisory authority over the federal courts to prescribe binding rules of evidence and procedure. While Congress has ultimate authority to modify or set aside any such rules that are not constitutionally required, it may not supersede this Court's decisions interpreting and applying the Constitution...

This Court declines to overrule Miranda... Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture. While the Court has overruled its precedents when subsequent cases have undermined their doctrinal underpinnings, that has not happened to Miranda."

The United States Supreme Court reversed the United States Court of Appeals for the Fourth Circuit judgment.

Justice Vote: 7 Pro vs. 2 Con
  • Rehnquist, W. Pro (Wrote majority opinion)
  • Stevens, J. Pro (Joined majority opinion)
  • O'Connor, S. Pro (Joined majority opinion)
  • Kennedy, A. Pro (Joined majority opinion)
  • Souter, D. Pro (Joined majority opinion)
  • Ginsburg, R. Pro (Joined majority opinion)
  • Breyer, S. Pro (Joined majority opinion)
  • Scalia, A. Con (Wrote dissenting opinion)
  • Thomas, C. Con (Joined dissenting opinion)
  • V. A WIN OR LOSS FOR THE ACLU?

    The ACLU, as amicus curiae, urged reversal of the judgment of the United States Court of Appeals for the Fourth Circuit; the Supreme Court reversed in a 7-2 vote, giving the ACLU an apparent win.