Discuss how Miranda v. Arizona and subsequent rulings apply.
Answer
[Your Name]
[Course Name and Number]
Project 4: Miranda v. Arizona Analysis
Date of Submission
MEMORANDUM OF LAW
I. Statement of the Facts
On [date], a team of eight police officers executed a search warrant at the apartment of a suspected drug trafficker with a history of illegal firearm possession. Upon entering the apartment, the officers conducted a swift sweep to account for all individuals present and discovered the suspect reclining in a chair in the living room. The suspect was immediately handcuffed and informed about the purpose of the search. In response to the question, “Is there anything we need to be aware of?”, the suspect disclosed the presence of eight loaded semi-automatic pistols under the bed in the master bedroom. Subsequently, officers found drug paraphernalia and unused bullets nearby. Over the course of eight hours, the officers discovered illicit weapons, drugs, and money in various locations within the apartment. Roughly 80 minutes into the search, the suspect asked an officer why he was being singled out and jokingly mentioned his cousin, “Vinny the Lawyer”. Another officer then inquired if there was more to discover, to which the suspect replied affirmatively and directed them to a closet filled with shoeboxes containing cocaine and marijuana. Only after two hours from the initiation of the search did an officer finally read the suspect his Miranda warnings.
II. Issues Presented
The key issues in this case revolve around the admissibility of the suspect’s statements and the evidence seized during the execution of the search warrant. Specifically, the questions are:
- Whether the suspect’s initial disclosure of the location of firearms under the bed and subsequent disclosure of drugs in the closet were voluntary and admissible under Miranda v. Arizona?
- Whether the statements made by the suspect regarding his cousin “Vinny the Lawyer” and the question about being picked on are admissible under Miranda?
- Whether the evidence of the pistol and the shoeboxes containing cocaine and marijuana should be suppressed due to the delayed administration of Miranda warnings?
III. Summary of Relevant Case Law
A. Miranda v. Arizona, 384 U.S. 436 (1966): The Supreme Court held that statements made by a suspect during custodial interrogation are admissible only if the suspect has been informed of their rights, including the right to remain silent and the right to an attorney. The warnings must be provided before questioning, and any waiver of these rights must be voluntary, knowing, and intelligent.
B. Rhode Island v. Innis, 446 U.S. 291 (1980): The Court extended the concept of “interrogation” beyond direct questioning to include any actions or words by law enforcement that are likely to elicit an incriminating response.
C. Berghuis v. Thompkins, 560 U.S. 370 (2010): The Court ruled that a suspect’s silence during questioning does not automatically invoke the right to remain silent; a suspect must explicitly invoke this right.
IV. Application of Relevant Law to the Facts
A. The initial disclosure of firearm location: The suspect’s voluntary disclosure of the firearms’ location was made before Miranda warnings were administered. However, this disclosure was not in response to direct questioning; it was in response to the general inquiry if there was anything the officers needed to know. This falls outside the definition of “interrogation” as per Rhode Island v. Innis.
B. Statements about “Vinny the Lawyer” and being picked on: These statements were made voluntarily, seemingly as casual conversation. The suspect was not subjected to custodial interrogation at the time, and thus, Miranda warnings were not required.
C. Disclosure of drugs in the closet: While the suspect was in custody for a significant period before being read his Miranda rights, the disclosure of the drugs followed a voluntary exchange where the suspect was not explicitly coerced or interrogated. The two-hour delay in administering the warnings does raise concerns, but under Berghuis v. Thompkins, the suspect’s silence during this time cannot be assumed to indicate a desire to remain silent.
V. Conclusion
In light of the foregoing analysis and the relevant case law, it is likely that the Court will not grant the motion to suppress the statements made by the suspect or the evidence seized during the search. The suspect’s initial disclosures were voluntary and made in non-interrogative contexts, and the subsequent disclosures were also made voluntarily without overt coercion. The two-hour delay in administering Miranda warnings, while not ideal, does not automatically render the evidence inadmissible, especially considering the suspect’s voluntary participation in discussions during that time.
Resource Page
- Miranda v. Arizona, 384 U.S. 436 (1966).
- Rhode Island v. Innis, 446 U.S. 291 (1980).
- Berghuis v. Thompkins, 560 U.S. 370 (2010).
[Additional resources used for research, if applicable, following APA citation format.]
Question
Description
Project 4
Students will analyze the following fact pattern and discuss how Miranda v. Arizona and subsequent rulings apply.
Eight police officers storm an apartment of a suspected drug trafficker with a history of illegal firearm possession. The officers, exercising a valid search warrant, conduct a quick sweep of the apartment to account for all individuals inside, discovering the suspect in the living room reclining in a chair. The officers immediately handcuff the suspect, place him in an upright position, and explain the reason for being there. Then, the officers asked the suspect, “Is there anything we need to be aware of?” The suspect responds that eight loaded semi-automatic pistols are under the bed in the master bedroom. Officers also find nearby, used drug paraphernalia and eight boxes of unused bullets. Over the course of eight hours the officers discover various amounts of illicit weapons, drugs, and money throughout the dwelling. After about 80 minutes into the raid, the suspect asks a nearby officer, “Why are you picking on me?” and asks in jest whether he should call his cousin “Vinny the Lawyer”. Another officer proceeds to ask the suspect if there was “more to find”. The suspect says “yes” and then leads them to a closet full of shoeboxes containing cocaine and marijuana. After the second exchange, and two hours after entering the dwelling, one of the officers reads the suspect his Miranda warnings.
The defense attorney has filed a motion to suppress each of the statements made by the suspect and the pistol and shoeboxes containing cocaine and marijuana seized during the execution of the warrant. Please do a 3-4 page memorandum of law evaluating the issues raised and citing appropriate authority and case law in support of your opinion as to whether or not the Court should grant the motion as to the statements and evidence seized. Your memorandum should include a statement of the facts, the issues presented, summary of relevant case law, application of the relevant law to the facts of this case and a conclusion.
Format:
- A minimum of 3 (maximum of 4) full pages of narrative text that responds to the items listed above
- Use American Psychological Association (APA) citation format for all narrative and Resource page citations, including judicial rulings.
- Double-spaced, 12 font, 1″ margins
- Cover Page: student’s name, name and number of the course, name of the project, date of submission
- Resource page: Any resources, including course instructional materials, referenced in this project, using APA citation formatting.