Dickerson v. United States (2000)
In this case about the rights of criminal suspects, the Court ruled on whether Congress could legislatively “overrule” one of the Court’s decisions.
Anyone who has ever watched Law and Order-type shows knows the familiar police phrase: “You have the right to remain silent.” That statement and others that follow about the right to a lawyer are commonly known as “Miranda Rights.” The Fifth Amendment protects an accused person’s right not to incriminate himself, and the Sixth Amendment protects the right to have a lawyer’s help in one’s criminal defense.
In a case from the 1960s, Ernesto Miranda was suspected of kidnapping and rape. He was interrogated by police and confessed to the crimes. The Supreme Court overturned Miranda’s conviction because he had not been adequately informed by police that he had the right to remain silent, or that he had the right to legal counsel. The phrase “Miranda Warnings” or “Miranda Rights” comes from that case, Miranda v. Arizona (1966). The Supreme Court held that if police do not inform suspects of their rights while they are in police custody, statements made by the suspects may not be used against them later at their trials.
Two years after the ruling in Miranda, Congress passed a law stating that federal judges must allow confessions by suspects to be used at trial if the confessions were made voluntarily. In other words, if a suspect confessed on their own (as opposed to admitting the crime while being interrogated), then the confession could be used in Court, even if police had not read the suspect his or her Miranda rights. Some believe this law was designed to overrule the Miranda ruling, while others believe it does not contradict the Miranda ruling at all since it only involves voluntary confession that were not part of an interrogation.
This federal law became an issue in a case in the 1990s: Dickerson v. United States. Dickerson was indicted for bank robbery. At his trial, Dickerson tried to have a confession he had made in an FBI field office suppressed, because he had not been read his rights. A Circuit Court upheld the federal law allowing voluntary confessions, reasoning that informing suspects of Miranda rights was not a constitutional requirement. The case went to the Supreme Court.
The Supreme Court ruled for Dickerson (7-2). Justice Rehnquist, writing for the majority, wrote: “Miranda, being a constitutional decision of this Court, may not be in effect overruled by an Act of Congress.” The Court also reasoned that Miranda warnings had become expected in the US: “Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture.”
The two dissenting Justices argued that there was nothing unconstitutional about using voluntary statements by defendants against them: “Preventing foolish (rather than compelled) confessions is likewise the only conceivable basis for the [ruling]… The Constitution is not, unlike the Miranda majority, offended by a criminal’s commendable qualm of conscience or fortunate fit of stupidity.”
Comprehension and Critical Thinking Questions
- Why is the case of Miranda v. Arizona (1966) important to understanding Dickerson v. United States (1999)?
- What were the facts of the case in Dickerson v. United States (1999), and how did the Court rule?
- The Fifth Amendment states in part, “nor shall [any person] be compelled in any criminal case to be a witness against himself, nor be deprived of life, liberty, or property, without due process of law.” What does “compelled” mean?
Using your definition of the term, would any of the following be “compelled” confessions?
A suspect confesses as soon as he sees police approaching him.
A suspect confesses as soon as police ask him where he was the night of the murder.
A suspect confesses as soon as he is arrested.
A suspect confesses after being promised something (e.g. a lighter sentence)
A suspect confesses after being threatened.
A suspect confesses after being physically tortured.
In your interpretation of this amendment, should voluntary confessions by suspects be admissible in federal court?
- The Supreme Court interpreted the Fifth and Sixth Amendments in Miranda v. Arizona (1966). Should Congress be able to pass laws that “overrule” a Supreme Court interpretation of the Bill of Rights?
- How does this case, in which the Supreme Court was asked to rule if Congress can overrule one of its rulings, test the Constitution’s separation of powers and checks and balances?