Miranda v. Arizona Timeline

Section 3501 of the 1968 Act was not ruled on for another 30 years because the Justice Department never attempted to rely on it to support the introduction of a confession into evidence at any criminal trial.

Case 222 (1971) held that a confession obtained in violation of the Miranda standards may nonetheless be used to impeach the defendant's testimony if the defendant takes the stand and the prosecution introduces the confession as a prior inconsistent statement.

Case 291 (1980) held that a 'spontaneous' statement made by a defendant while in custody, even without Miranda warnings or after invocation of the right to counsel, is admissible as long as it was not given in response to police questioning likely to produce an incriminating response.

Case 420 (1984) held that a person subjected to custodial interrogation is entitled to the benefit of the procedural safeguards enunciated in Miranda, regardless of the nature or severity of the offense suspected or for which he is arrested.

Case 649 (1984) held that there is also a 'public safety' exception to the requirement that Miranda warnings be given before questioning—for example, if the defendant possesses information about the location of an unattended gun or other exigent circumstances exist, responses may be admissible even without warnings.

Case 157 (1986) held that 'knowing, intelligent, and voluntary' waivers mean only that suspects reasonably appear to understand what they are doing and are not being coerced into signing; whether the suspect was actually cognitively or mentally impaired was ruled irrelevant.

Garibay (1998) clarified an important matter regarding the scope of Miranda, addressing how warnings must be understood by suspects for a valid waiver of their rights.

Case 428 (2000) addressed when the validity of Congress's overruling of Miranda through section 3501 was tested; the Supreme Court reaffirmed Miranda as a constitutional rule that Congress could not supersede by statute.

Case 600 (2004) saw the Supreme Court halt one of the more controversial practices, reinforcing limits on interrogation tactics incompatible with Miranda's protections.

In 2009, the California Supreme Court upheld the conviction of Richard Allen Davis, finding that the public-safety exception applied despite the fact that 64 days had passed from the disappearance of the girl later found to be murdered.

Image source: Richard Allen Davis

Thompkins (2010) was a ruling in which the Supreme Court held that a suspect's 'ambiguous or equivocal' statement, or lack of statements, does not mean that police must end an interrogation.

Under Thompkins (2010), a suspect must unambiguously invoke the right to remain silent or to counsel; silence alone will not stop an interrogation once a suspect has waived or not clearly asserted these rights.

In Tekoh (2022), the Supreme Court ruled 6–3 that police officers could not be sued under a particular statutory cause of action for failing to administer the Miranda warning, ruling that not every Miranda violation is a deprivation of a constitutional right.

Image source: Vega v. Tekoh