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Facts

The Supreme Court's decision in Miranda v. Arizona addressed four different cases involving custodial interrogations. In each of these cases, the defendant was questioned by police officers, detectives, or a prosecuting attorney in a room in which he was cut off from the outside world. In none of these cases was the defendant given a full and effective warning of his rights at the outset of the interrogation process. In all the cases, the questioning elicited oral admissions and, in three of them, signed statements that were admitted at trial.

Miranda v. Arizona: Miranda was arrested at his home and taken in custody to a police station where he was identified by the complaining witness. He was then interrogated by two police officers for two hours, which resulted in a signed, written confession. At trial, the oral and written confessions were presented to the jury. Miranda was found guilty of kidnapping and rape and was sentenced to 20-30 years imprisonment on each count. On appeal, the Supreme Court of Arizona held that Miranda's constitutional rights were not violated in obtaining the confession.

Vignera v. New York: Vignera was picked up by New York police in connection with the robbery of a dress shop that had occurred three days prior. He was first taken to the 17th Detective Squad headquarters. He was then taken to the 66th Detective Squad, where he orally admitted the robbery and was placed under formal arrest. He was then taken to the 70th Precinct for detention, where he was questioned by an assistant district attorney in the presence of a hearing reporter who transcribed the questions and answers. At trial, the oral confession and the transcript were presented to the jury. Vignera was found guilty of first degree robbery and sentenced to 30-60 years imprisonment. The conviction was affirmed without opinion by the Appellate Division and the Court of Appeals.

Westover v. United States: Westover was arrested by local police in Kansas City as a suspect in two Kansas City robberies and taken to a local police station. A report was also received from the FBI that Westover was wanted on a felony charge in California. Westover was interrogated the night of the arrest and the next morning by local police. Then, FBI agents continued the interrogation at the station. After two-and-a-half hours of interrogation by the FBI, Westover signed separate confessions, which had been prepared by one of the agents during the interrogation, to each of the two robberies in California. These statements were introduced at trial. Westover was convicted of the California robberies and sentenced to 15 years' imprisonment on each count. The conviction was affirmed by the Court of Appeals for the Ninth Circuit.

California v. Stewart: In the course of investigating a series of purse-snatch robberies in which one of the victims died of injuries inflicted by her assailant, Stewart was identified as the endorser of checks stolen in one of the robberies. Steward was arrested at his home. Police also arrested Stewart's wife and three other people who were visiting him. Stewart was placed in a cell, and, over the next five days, was interrogated on nine different occasions. During the ninth interrogation session, Stewart stated that he had robbed the deceased, but had not meant to hurt her. At that time, police released the four other people arrested with Stewart because there was no evidence to connect any of them with the crime. At trial, Stewart's statements were introduced. Stewart was convicted of robbery and first-degree murder and sentenced to death. The Supreme Court of California reversed, holding that Stewart should have been advised of his right to remain silent and his right to counsel.

Issues

Whether "statements obtained from an individual who is subjected to custodial police interrogation" are admissible against him in a criminal trial and whether "procedures which assure that the individual is accorded his privilege under the Fifth Amendment to the Constitution not to be compelled to incriminate himself" are necessary.

Supreme Court holding

The Court held that "there can be no doubt that the Fifth Amendment privilege is available outside of criminal court proceedings and serves to protect persons in all settings in which their freedom of action is curtailed in any significant way from being compelled to incriminate themselves." As such, "the prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way."

The Court further held that "without proper safeguards the process of in-custody interrogation of persons suspected or accused of crime contains inherently compelling pressures which work to undermine the individual's will to resist and to compel him to speak where he would otherwise do so freely." Therefore, a defendant "must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires."

The Supreme Court reversed the judgment of the Supreme Court of Arizona in Miranda, reversed the judgment of the New York Court of Appeals in Vignera, reversed the judgment of the Court of Appeals for the Ninth Circuit in Westover, and affirmed the judgment of the Supreme Court of California in Stewart.

Argued: Feb. 28, March 1 and 2, 1966

Decided: June 13, 1966

Vote: 5-4

Majority opinion written by Chief Justice Warren and joined by Justices Black, Douglas, Brennan, and Fortas.

Dissenting opinion written by Justice Harlan and joined by Justices Stewart and White.

Dissenting in part opinion written by Justice Clark.

Follow-Up

Miranda v. Arizona: After Miranda's conviction was overturned by the Supreme Court, the State of Arizona retried him. At the second trial, Miranda's confession was not introduced into evidence. Miranda was once again convicted and sentenced to 20-30 years in prison.

DISCLAIMER: These resources are created by the Administrative Office of the U.S. Courts for educational purposes only. They may not reflect the current state of the law, and are not intended to provide legal advice, guidance on litigation, or commentary on any pending case or legislation.

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Facts and Case Summary - Miranda v. Arizona

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Facts The Supreme Court's decision in Miranda v. Arizona addressed four different cases involving custodial interrogations. In each of these cases, the defendant was questioned by police officers, detectives, or a prosecuting attorney in a room in which he was cut off from the outside world.

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"Are police constitutionally required to inform people in custody of their rights to remain silent and to an attorney?" was the question of this case.
The result being: the 5th and 6th Amendments require police to inform arrested individuals they have a right to remain silent and to be assisted by an attorney. According to the Court, if the police fail to do so, a criminal court judge may rule that any statements made by the accused cannot be admitted as evidence.

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Separate But Equal Doctrine

In 1896, the Supreme Court ruled in Plessy v. Ferguson that racially segregated public facilities were legal, so long as the facilities for Black people and whites were equal.

The ruling constitutionally sanctioned laws barring African Americans from sharing the same buses, schools and other public facilities as whites-known as "Jim Crow" laws -and established the "separate but equal" doctrine that would stand for the next six decades.

But by the early 1950s, the National Association for the Advancement of Colored People ( NAACP) was working hard to challenge segregation laws in public schools, and had filed lawsuits on behalf of plaintiffs in states such as South Carolina, Virginia and Delaware.

In the case that would become most famous, a plaintiff named Oliver Brown filed a class-action suit against the Board of Education of Topeka, Kansas, in 1951, after his daughter, Linda Brown, was denied entrance to Topeka's all-white elementary schools.

In his lawsuit, Brown claimed that schools for Black children were not equal to the white schools, and that segregation violated the so-called "equal protection clause" of the 14th Amendment, which holds that no state can "deny to any person within its jurisdiction the equal protection of the laws."

The case went before the U.S. District Court in Kansas, which agreed that public school segregation had a "detrimental effect upon the colored children" and contributed to "a sense of inferiority," but still upheld the "separate but equal" doctrine.

Brown v. Board of Education Verdict

When Brown's case and four other cases related to school segregation first came before the Supreme Court in 1952, the Court combined them into a single case under the name Brown v. Board of Education of Topeka.

Thurgood Marshall, the head of the NAACP Legal Defense and Educational Fund, served as chief attorney for the plaintiffs. (Thirteen years later, President Lyndon B. Johnson would appoint Marshall as the first Black Supreme Court justice.)

At first, the justices were divided on how to rule on school segregation, with Chief Justice Fred M. Vinson holding the opinion that the Plessy verdict should stand. But in September 1953, before Brown v. Board of Education was to be heard, Vinson died, and President Dwight D. Eisenhower replaced him with Earl Warren, then governor of California.

Displaying considerable political skill and determination, the new chief justice succeeded in engineering a unanimous verdict against school segregation the following year.

In the decision, issued on May 17, 1954, Warren wrote that "in the field of public education the doctrine of 'separate but equal' has no place," as segregated schools are "inherently unequal." As a result, the Court ruled that the plaintiffs were being "deprived of the equal protection of the laws guaranteed by the 14th Amendment."

Little Rock Nine

In its verdict, the Supreme Court did not specify how exactly schools should be integrated, but asked for further arguments about it.

In May 1955, the Court issued a second opinion in the case (known as Brown v. Board of Education II), which remanded future desegregation cases to lower federal courts and directed district courts and school boards to proceed with desegregation "with all deliberate speed."

Though well intentioned, the Court's actions effectively opened the door to local judicial and political evasion of desegregation. While Kansas and some other states acted in accordance with the verdict, many school and local officials in the South defied it.

In one major example, Governor Orval Faubus of Arkansas called out the state National Guard to prevent Black students from attending high school in Little Rock in 1957. After a tense standoff, President Eisenhower deployed federal troops, and nine students-known as the " Little Rock Nine"- were able to enter Central High School under armed guard.

Impact of Brown v. Board of Education

Though the Supreme Court's decision in Brown v. Board didn't achieve school desegregation on its own, the ruling (and the steadfast resistance to it across the South) fueled the nascent civil rights movement in the United States.

In 1955, a year after the Brown v. Board of Education decision, Rosa Parks refused to give up her seat on a Montgomery, Alabama bus. Her arrest sparked the Montgomery bus boycott and would lead to other boycotts, sit-ins and demonstrations (many of them led by Martin Luther King Jr.), in a movement that would eventually lead to the toppling of Jim Crow laws across the South.

Passage of the Civil Rights Act of 1964, backed by enforcement by the Justice Department, began the process of desegregation in earnest. This landmark piece of civil rights legislation was followed by the Voting Rights Act of 1965 and the Fair Housing Act of 1968.

In 1976, the Supreme Court issued another landmark decision in Runyon v. McCrary, ruling that even private, nonsectarian schools that denied admission to students on the basis of race violated federal civil rights laws.

By overturning the "separate but equal" doctrine, the Court's decision in Brown v. Board of Education had set the legal precedent that would be used to overturn laws enforcing segregation in other public facilities. But despite its undoubted impact, the historic verdict fell short of achieving its primary mission of integrating the nation's public schools.

Today, more than 60 years after Brown v. Board of Education, the debate continues over how to combat racial inequalities in the nation's school system, largely based on residential patterns and differences in resources between schools in wealthier and economically disadvantaged districts across the country.

HISTORY Vault: Black History

Sources

History - Brown v. Board of Education Re-enactment, United States Courts.
Brown v. Board of Education, The Civil Rights Movement: Volume I (Salem Press).
Cass Sunstein, "Did Brown Matter?" The New Yorker, May 3, 2004.
Brown v. Board of Education, PBS.org.
Richard Rothstein, Brown v. Board at 60, Economic Policy Institute, April 17, 2014.

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Brown v. Board of Education: Summary, Ruling & Impact | HISTORY

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Brown v. Board of Education of Topeka was a landmark 1954 Supreme Court case in which the justices ruled unanimously that racial segregation of children in public schools was unconstitutional.

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Scott vs. Standford

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McCulloch v. Maryland

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The issue that court was dealing with was, "Do racially segregated public schools violate the Equal Protection Clause?"
The court decided: Yes, state laws requiring or allowing racially segregated schools violate the Equal Protection Clause of the 14th Amendment.

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The issue that was faced in this case was, "Does Congress have the constitutional power to prohibit slavery in free territories?" The result of the case was no, Congress could not prohibit slavery in territories

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The issue being faced in this case was,"Can facilities be segregated based upon race?"
The court decided, yes, legalized racial segregation in publicly owned facilities on the basis of "separate but equal."

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EnlargeDownload Link Citation: Judgment in the U.S. Supreme Court Case Dred Scott v. John F. A. Sandford; 3/6/1857; Dred Scott, Plaintiff in Error, v. John F. A. Sandford; Appellate Jurisdiction Case Files, 1792 - 2010; Records of the Supreme Court of the United States, Record Group 267; National Archives Building, Washington, DC. View All Pages in National Archives Catalog View Transcript In this ruling, the U.S. Supreme Court stated that enslaved people were not citizens of the United States and, therefore, could not expect any protection from the federal government or the courts.

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The issue in this case was, "Can Congress establish a national bank, and if so, can a state tax this bank?" When making it's decision,The Court held that Congress had implied powers to establish a national bank under the "necessary and proper" clause of the U.S. Constitution. The Court also determined that United States laws are superior to state laws, states could not tax the national bank