The Case of Vignera v. New York and the Case of Miranda v. Arizona - Paper Example

III. FACTS:

The case mentioned above encompassed for different cases which were enjoined in a law suit with the thematic concern of the ideal procedures that ought to be adopted during custodial interrogations. Each defendant admitted to having being questioned by either a prosecuting attorney, detectives or police officer in a room that secluded them from the outside world (The OYEZ Project, 2017). The fundamental issue was the fact that the respondents were subjected to the various form of interrogation techniques without being an informed consent on their rights as stipulated in the American Constitution.

In the case of Vignera v. New York, the respondent was apprehended by the New York police about robbery that had occurred in a dress shop. The suspect was questioned by various representatives from different law enforcement agencies including the 17th and 66th Detective Squad. Finally, Vignera orally admitted to the allegations brought against him in the presence of the assistant district attorney and a reporter who transcribed the confession. The confession was admitted as evidence in the case where the victim was sentenced to between 30-60 years for the first-degree robbery (Ainsworth, 2010). The case of Westover v. the United States involved the arrest by the local police in Kansas City where the suspect was linked to two separate robberies. Moreover, as the statement from the FBI designated that Westover was liable for felony charges in California. After a prolonged interrogation without any form of consent, the defendant was asked to sign separate confessions that had been prepared by the investigators. These signed statements were utilized as evidence in court, and the respondent was sentenced to 15 years in jail. In the case of California v. Stewart, the defendant was found in contravention with the law by endorsing checks that were stolen from victims who had later succumbed to the injuries inflicted on them following a purse-snatch. Stewart was then interrogated over the course of 5 days, and it is at the 9th interrogation session that the defendant admitted to having robbed the victims, but it was not his intention to hurt them (Kamisar, 2007). Stewarts statements were introduced in the trial which assisted in his conviction for stealing and first-degree homicide where he was handed the death penalty. Later, the Supreme Court of California reversed this verdict on the premise that the defendant was not advised accordingly before his the commencement of his interrogation.

Perhaps the most significant of these cases is the one involving Miranda v. Arizona hence the advent of the Miranda warning as a guide that protects a suspects legislative autonomy during interrogations. Miranda was apprehended at his residence and was taken into custody where he was identified by a witness during a lineup. The subsequent questioning resulted in a written confession that was used by the jury during the sentencing process. Miranda was found culpable for the charges of rape and kidnapping where he was sentenced to between 20-30 years.

IV. LEGAL ISSUE:

Is the privilege of the Fifth Amendment protection against self-accusation extended to safeguard the rights of suspects during interrogation? What does the provision in the Constitution encompass in regards to the right to representation during custodial interrogations?

V. COURT DECISION:

In the case of Miranda v. Arizona, the ruling was delivered in 1966 by a 5-4 majority where the Supreme Court held that the Fifth Amendment injunction against admission of guilt was practical to an individual who was detained by the police. In a bid to guarantee this right, the court also ruled that a suspect ought to be informed before an interrogation of his right to remain mute and the admissibility of his actions in court (Smith, 2010). Further, the defendant would be entitled to legal representation, and if they are financially incapable of affording an attorney, one will be provided by the state. Justices Warren, Black, Douglas, Brennan, and Fortas represented the majority faction while Justices Harlan, Stewart and White dissented the decision.

VI. OPINION AND REASONING OF THE COURT: (by Justice Warren)

The majority of the tribunals opinion was delivered by Chief Justice Warren who observed the contentious inquiries in regards to criminal justice during the prosecution of perpetrators. In essence, the ruling broadly encompassed the acceptability of the statements retrieved from an individual. In addition to this, the verdict recognized the ideal procedures that need to be instituted in a bid to uphold the provisions embedded in the Fifth Amendment that protects an individual against coercion towards self-incrimination.

The principles of the courts rationality was evidenced in the landmark case of Escobedo v. Illinois, 378 U.S. 478 (1964). In this case, the defendant was taken into custody where the sole purpose of the interrogation was to obtain a written confession. Nonetheless, the law enforcement officer did not apprise the offender on his right to remain hushed nor was he conversant of the right to an attorney (Zalman & Smith, 2007). Instead, the suspect was confronted with a purported accomplice who accused him of murder. The officers went to the extent of preventing Escobedos retained lawyer from consulting with him, and when his confession was introduced as evidence, the court held that such proof was constitutionally inadmissible. In this regard, the prosecution is advised to refrain from statements obtained in an errant manner during interrogations. Such a guideline enforces the need of securing the right of the suspect against self-incrimination in the event of that one is taken into custody as is defined by the Fifth Amendment (Strauss, 2007). Thus, before the start of the interrogation process, the suspect needs to be cautioned on the autonomy of the suspect and any evidence that will be collected against him hence forth with be taken up as evidence in a court of law including suspects right to an attorney who may be either appointed or retained. The individual may waive the rights above if they deem it necessary as long as they make such decisions intelligently, voluntarily and in total awareness of the implications of their decisions. On the other hand, if the individual indicates that he desires the services of a lawyer before being interviewed, the questioning process ought to be halted. Similarly, if a person shows that he does not wish to be questioned, he enjoys the right from further examination despite volunteering to offer on his initial statements.

The constitutional issues mentioned above denote the admissibility of the statements and the approaches adopted in acquiring the confessions from the suspects. In the case of Miranda v. Arizona, the police officers were found to have failed to inform the defendant of his right to remain silent before the beginning of the interrogation. Their actions resulted in an oral confession by the perpetrator who was then admitted as evidence in court. Thus, the prominent features, in this case, include incommunicado interrogation where the suspects were held in the police dominated setting. Accordingly, this culminated in self-incriminating accounts without elaborate warnings by the American Constitution.

VII. CONCURRING OPINION (by Justice Douglas)

In regards to the case of Vignera v. New York, the respondent was found culpable of first-degree murder and was handed a 20-30 years in jail based on an oral confession. Moreover, this decision was upheld by the Court of Appeals and the Appellate Division without any form of consultation. In essence, the State was deemed it fit to deny Vignera the constitutional right of access to counsel or safeguarding the right against self-incrimination. As such, Justice Douglas called for a reversal of the decision on the basis that Vignera was not forewarned on his rights prior to the inquiry by the investigators and assistant attorney. Besides, no extra procedures were taken to guarantee these rights which resulted in the violation of the Fifth Amendment of the right to legal counsel thus his confession may be deemed as irrelevant in a court of law (Wrightsman & Pitman, 2010). In the case of Westover v. United, the perpetrator was given 15 years in prison on each count of two separate robberies following Westovers confession. Consequently, this prompted a reversal from on appeal since the court was unable to substantiate whether the suspect had willingly waived his right to counsel and whether he was notified of his right to remain silent before issuing a confession.

VIII. DISSENTING OPINION (delivered by Justice Clark)

Justice Clark proposes that his counterparts who undertook the majority decision went too little too far. This implies that despite the rigorous nature that the techniques employed by investigators were flawed, the Court had sanctioned additional approaches such as the right to consult a lawyer and the conventional warning before beginning the interrogation process. Moreover, the Court endorses a constitutional rule which prevent the police from executing their duties to full effect. Such a phenomenon may be attributed to the rights of the suspect as enshrined under the Fifth Amendment which when invoked, the interrogation has to be terminated. Hence, the court sensitizes that if the novel procedures of warning the suspect of his rights are not adopted, then the statements that had been made earlier may be discarded since they are constitutionally inadmissible (Weisselberg, 2008). Such a strict constitutional measure may prove to be deterrent in the efforts geared towards crime detection by stalling the process. Additionally, custodial interrogation has played a vital role in law enforcement and as such the ruling in Escobedo v. Illinois was fundamentally based on the conglomeration of the evidence supporting the involuntary admission of guilt (Allen, 2007). Thus, the detection and solution of a particular crime is at the very least a daunting task for law enforcement officers since a thin line exists between the ideal and permissible police conduct. Perhaps this may be evidenced in the exceptional cases where it is mandatory to effect coercive psychological inducements to gain a sense of cooperation of the suspect.

IX. SEPARATE DISSENTING OPINION (by Justices Harlan, Stewart and White)

The judges admitted that there exists ambiguity in the new directives formulated by the court in the sense that admissions and exculpatory statements are regarded as confessions, the burden of proof in regards to a waiver of the suspects rights rests with the state including the permissibility of withdrawing ones waiver. Such a decision infers the issue of double standards as the statutes developed are not aimed at safeguarding the defendants from police brutality or other forms of coercion. Rather, the primary focus is seemingly directed towards negating all sorts of pressures, discouraging a confession from the suspect and reinforcing the notions of an ignorant suspect (Lewis, 2007). In addition to this, a scrutiny of the legal standards is deemed necessary insofar as the limits on confessions in Court is concerned. Accordingly, the provisions of the Due Process Clause and the Fourteenth Amendment would suffice since they provide an elaborate picture in the practical and workable means of handling confessions judicially (Rogers, 20111). Equally important is the fact that the court acts on the assumption that precise comprehension of ones rights is a precondition under the Fifth Amendment to the potential loss in its securities. Some lower federal court cases such as United States v. Scully, 255 F.2d 113, 116 have given direction based that the grand jury witnesses need not be informed of their right t...