Dickerson v. United States (2000)
Supreme Court of the United States
Charles Thomas Dickerson v. United States
Decided June 26, 2000 – 530 U.S. 428
Chief Justice REHNQUIST delivered the opinion of the Court.
[Examining validity of a congressional statute indicating that federal law enforcement officers are not obligated to give Miranda warnings]
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Whether or not we would agree with Miranda’s reasoning and its resulting rule, were we addressing the issue in the first instance, the principles of stare decisis weigh heavily against overruling it now. While “‘stare decisis not an inexorable command,’” particularly when we are interpreting the Constitution, “even in constitutional cases, the doctrine carries such persuasive force that we have always required a departure from precedent to be supported by some ‘special justification.’”
We do not think there is such justification for overruling Miranda. Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture. While we have overruled our precedents when subsequent cases have undermined their doctrinal underpinnings, we do not believe that this has happened to the Miranda decision. If anything, our subsequent cases have reduced the impact of the Miranda rule on legitimate law enforcement while reaffirming the decision’s core ruling that unwarned statements may not be used as evidence in the prosecution’s case in chief.
The disadvantage of the Miranda rule is that statements which may be by no means involuntary, made by a defendant who is aware of his “rights,” may nonetheless be excluded and a guilty defendant go free as a result…..
In sum, we conclude that Miranda announced a constitutional rule that Congress may not supersede legislatively. Following the rule of stare decisis, we decline to overrule Miranda ourselves. The judgment of the Court of Appeals is therefore [r]eversed.
Justice SCALIA, with whom Justice THOMAS joins, dissenting. [omitted]
Notes, Comments, and Questions
When given the opportunity, the Court did not overrule Miranda. Do you agree that Miranda warnings should still be required? Why or why not?
Our next chapters explore two important questions left open by Miranda—how the Court would define “custody” and how it would define “interrogation.” Because the Miranda Rule applies only during “custodial interrogation,” each of these definitions is essential to applying the rule.