While he was in state prison, the petitioner was visited and questioned by an agent from the Internal Revenue Service for a ‘‘routine investigation’’ of tax returns he filed in 1960 and 1961. Without being warned of his right to remain silent, his right to counsel, or that any information he might give could be used against him, the petitioner responded to the agent’s questions. Statements and documents obtained from the petitioner during these visits were later used as evidence to convict him of knowingly filing false tax returns. The court of appeals affirmed the conviction.
The U.S. Supreme Court reversed. Pursuant to its decision in Miranda v. Arizona, 348 U.S. 436 (1966), the Court held that when an individual is in government custody and interrogated on matters that may incriminate him, he must be warned beforehand of his right to remain silent and his right to counsel. Any information obtained, absent these warnings, must be excluded from trial. The Court’s decision therefore extended the Miranda warning requirement in two important ways. First, it was made clear that tax investigations of people in government custody necessitate a Miranda warning. Under the Court analysis, since tax investigations are often made in contemplation of a criminal prosecution, the person under investigation needs to be warned of his or her rights. Second, the Court’s decision made it clear that a Miranda warning is required to be given to a person in custody even when, as here, the investigation is unconnected to the reason why the person is in custody.
References and Further Reading
Cases and Statutes Cited
See also Coerced Confessions/Police Interrogations; Miranda Warning; Self-Incrimination: Miranda and Evolution