Prior to the leading case of Miranda v. Arizona, 384 U.S. 436, decided in 1966, the U.S. Supreme Court used the standard of ‘‘voluntariness’’ in determining the admissibility of a confession. The Miranda decision replaced this standard in most cases with a prescribed set of warnings that must be given prior to custodial interrogation. Failure to give the warnings would render a confession inadmissible, even if it were given voluntarily.
In the midst of the widespread criticism that Miranda generated, Congress enacted 18 U.S.C. section 3501, which purported to overturn Miranda insofar as it applied in federal criminal cases. Under the statute, which was totally ignored for thirty years, the failure to give the warnings did not prevent a confession from being admitted as long as it was voluntary.
In Dickerson v. United States the trial court granted Dickerson’s motion to suppress a statement he made to the F.B.I. on the ground that the Miranda warnings had not been given. The Fourth Circuit Court of Appeals reversed, holding that under section 3501 the confession was voluntary and therefore admissible. In reversing the court of appeals, the U.S. Supreme Court held that the rule in Miranda was based on the Constitution and, as such, could not be overruled by an act of Congress. The Court refused to overrule Miranda on its own, finding that it has become part of routine police procedures and that subsequent cases have reaffirmed Miranda’s core ruling while reducing its negative impact on legitimate police practices.
STEVEN B. DOW
References and Further Reading
Cases and Statutes Cited