Dickerson v. United States
| Dickerson v. United States | |
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| Argued April 19, 2000 Decided June 26, 2000 |
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| Full case name | Charles Thomas Dickerson, Petitioner v. United States |
| Citations | 530 U.S. 428 (more) |
| Holding | |
| The mandate of Miranda v. Arizona that a criminal suspect be advised of certain constitutional rights governs the admissibility at trial of the suspect's statements, not the requirement of 18 U.S.C. § 3501 that such statements simply be voluntarily given. | |
| Court membership | |
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| Case opinions | |
| Majority | Rehnquist, joined by Stevens, O'Connor, Kennedy, Souter, Ginsburg, Breyer |
| Dissent | Scalia, joined by Thomas |
| Laws applied | |
| U.S. Const. amend. V | |
Dickerson v. United States, 530 U.S. 428 (2000), upheld the requirement that the Miranda warning be read to criminal suspects and struck down a federal statute that purported to overrule Miranda v. Arizona (1966).
The Court noted that neither party in the case advocated on behalf of the constitutionality of 18 U.S.C. § 3501, the specific statute at issue in the case. Accordingly, it invited Paul Cassell, a former law clerk to Antonin Scalia and Warren E. Burger, to argue that perspective. Cassell was then a professor at the University of Utah law school; he was later appointed to, and subsequently resigned from, a federal district court judgeship in that state.
In Miranda v. Arizona, the Supreme Court held that statements of criminal suspects made while they are in custody and subject to interrogation by police may not be admitted in court unless the suspect first had certain warnings read to him beforehand. By now, these warnings are familiar to most Americans: that the suspect has the right to remain silent during the interrogation, that anything he says to the police may be used against him in a court of law, that he has the right to legal counsel, and that if he cannot afford legal counsel a lawyer will be provided for him.
In 1968, two years after the Miranda decision, Congress passed a law that purported to overrule it as part of the Omnibus Crime Control and Safe Streets Act of 1968. This statute, 18 U.S.C. § 3501, directed federal trial judges to admit statements of criminal defendants if they were made voluntarily, without regard to whether he had received the Miranda warnings. Under § 3501, voluntariness depended on such things as (1) the time between arrest and arraignment, (2) whether the defendant knew the crime for which he had been arrested, (3) whether he had been told that he did not have to talk to the police and that any statement could be used against him, (4) whether the defendant knew prior to questioning that he had the right to the assistance of counsel, and (5) whether he actually had the assistance of counsel during questioning. However, the "presence or absence of any of" these factors "need not be conclusive on the issue of voluntariness of the confession." Because § 3501 was an act of Congress, it applied only to federal criminal proceedings and criminal proceedings in the District of Columbia.
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