Standing Up for Miranda

The U.S. Supreme Court’s unanimous decision this week restating the rules for use of the so-called Miranda warning broke no new legal ground. Rather, the strong opinion is notable for the justices’ repudiation of a poor decision handed down last year by the California Supreme Court and for their rebuke to the police officers and prosecutors in the case at issue.

The California case centered on the murder of Robyn Jackson, 10, who disappeared from a Baldwin Park playground on Sept. 28, 1982; her body was discovered the next morning. Soon afterward, police officers went to the trailer of Robert Stansbury, an ice cream truck driver the girl was seen talking with before she vanished. Police considered him a possible witness, not a suspect, and asked him to go to the police station to answer questions. Stansbury agreed.

Since 1966, the Supreme Court has required that individuals taken into custody be issued a warning that includes notice they have the right to remain silent, that their words may be used against them and that they have the right to have an attorney present during questioning. Without such a warning, no evidence obtained in an interrogation may be used against an accused.

During questioning, Stansbury said that on the night of the murder he had driven an automobile matching the description of the car from which a witness saw the child’s body dumped. After he disclosed he had been convicted of rape, kidnaping and child molestation, the police read Stansbury his Miranda rights and charged him with murder.

Stansbury then tried to suppress his statements. He eventually was convicted in the Baldwin Park case, and the jury determined that he should be executed. The trial court ruled that Stansbury was not “in custody”--and thus not entitled to a Miranda warning--until he mentioned his use of the car. The California Supreme Court agreed but, this week, the U.S. Supreme Court did not. The U.S. court emphatically and correctly reminds judges and law enforcement officials that custody depends on the objective circumstances of the interrogation, not the subjective views of those present. Even in the prosecution of heinous crimes, basic constitutional rights cannot be abridged.