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Elena Kagan and the Death of Miranda

Posted: 06/01/10 03:45 PM ET

On June 1, the U.S. Supreme Court finally dealt Miranda a death blow. Elena Kagan, Obama's nominee for the Supreme Court, was complicit in Miranda's demise. Her participation may give some insight into her views on the rights of criminal defendants, and her understanding of how the law affects ordinary people.

In Berghuis v. Thompkins, the decision announced today, the Court ruled 5-4 that a suspect has to speak in order to assert the right to remain silent. Van Chester Thompkins was given his Miranda warnings and remained quiet for almost 3 hours. During that time, officers continued the interrogation and Thompkins eventually made an admission. A federal court found that he had asserted his right to remain silent by actually remaining silent, and that officers should have ended the questioning. The Supreme Court reversed.

The majority said that if officers give Miranda warnings to a suspect, they may begin questioning and continue to question unless the person clearly and unambiguously says he wants to remain silent or wants a lawyer. Police do not have to expressly ask a suspect to waive their rights. If the person shows incredible stamina -- like Thompkins -- and manages to remain silent through hours of intense interrogation, he will have "waived" his rights if he eventually caves in to pressure.

And the Court has placed a substantial burden on suspects to invoke their rights with great precision. A number of lower courts applying the clear and unambiguous standard have been quite demanding, finding that statements such as "I think it's about time for me to stop talking" and "I think I would like to talk to a lawyer" are not clear invocations of the right to remain silent or the right to counsel.

The Court's opinion is the most important Miranda decision in a decade. The ruling is breathtaking even to those, like me, who believe that Miranda's safeguards were already eroded. The Court has formally transformed Miranda from a rule aimed at protecting suspects to one that protects police. Miranda's safeguards for suspects are now mostly symbolic. So long as officers give warnings, their interrogation practices will be largely immune from any legal challenge. As the justices have noted in other cases, if warnings are given and a statement is obtained, it is very difficult for a defendant to contend that his admissions were coerced.

Justice Sotomayor wrote a strong dissent in Thompkins. Joined by retiring Justice John Paul Stevens and Justices Breyer and Ginsburg, she explained how the majority opinion rewrites Miranda.

So what was Kagan's role? As Solicitor General, she filed a brief in Berghuis v. Thompkins for the United States as amicus curiae (friend of the Court). The U.S. was not a party in the case since Thompkins had been convicted in state court and it was the State of Michigan that challenged the lower court's ruling. Kagan did not have to enter the fray and take a position, but she decided to do so.

Kagan's brief was even more aggressive than Michigan's. In a 1994 case, Davis v. United States, the justices ruled that if a suspect first waives his rights and then later wants a lawyer, the person has to invoke that right clearly in order to require officers to stop questioning. Kagan's position -- accepted by the majority in Thompkins -- was that Davis should be extended to the right to remain silent and to cases where a person has not already waived his or her rights. By contrast, the State of Michigan sought to win on a narrower ground. We cannot know whether Kagan's arguments convinced the majority to issue such a broad decision. But the Solicitor General, often called the "Tenth Justice," is a very influential player.

What does this case tell us about a Supreme Court with Justice Kagan? Superficially, if Kagan had already replaced Stevens on the Court, the outcome would not have changed. At most, the decision would have been 6-3 and not 5-4. But Kagan's arguments may reveal something else, particularly when contrasted with Sotomayor's dissent.

Kagan's brief shows no understanding of modern police interrogation tactics or that suspects -- who are in a position of powerlessness during an interrogation -- may have difficulty asserting their rights or using precise language to do so. Sotomayor, on the other hand, notes that "criminal suspects often use equivocal or colloquial language in attempting to invoke their right to silence." Her dissent reveals a solid understanding of how the decision will shape police practices. Of course, Sotomayor was a prosecutor and a trial judge. Kagan has no experience on the ground.

In nominating Elena Kagan to the Supreme Court, President Obama said that Kagan has an "understanding of law, not as an intellectual exercise or words on a page, but as it affects the lives of ordinary people..." Perhaps so. But that understanding was not evident in Kagan's work in Thompkins.

 
 
 
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11:06 PM on 06/03/2010
Heret's the problem. The above article doesn't tell you that he answered several questions with one word answers before uttering the death blow answer of "yes," to the question, "did you pray to God and ask for forgiveness for shhoting that person?" To which his answer as mentioned before, was, "yes."
11:22 AM on 06/02/2010
If I stay silent for "almost three hours" during an interrogation, then that should mean that I have nothing to say.
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Brian25
Conservative without all the Jesus
11:12 AM on 06/02/2010
Nice job court. Score one for the victims of these criminals. Its amazing how many people are on the side of a murderer.
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doublels
say it out loud...I'm a Lib & I'm proud
12:34 PM on 06/02/2010
Brian...take a chill pill. NO one, lib or repub, etc. wants to see a guilty person go free. We all have empathy for victims. However, according to our laws, everyone is presumed innocent until prounounced guilty. We also all know, that everyone who is arrested is NOT always guilty. Nor, is everyone convicted always guilty. People are not infallible, ergo our justice system is not infallible.
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FREEDOM BELL
03:21 AM on 06/06/2010
Miranda rights are required before a person is arrested if they are merely a suspect. Many suspects are not guilty.

The police are not always right. As a group, they are not the nicest, most honest or the brightest people.

As this country slides into a police state, people have forgotten how things were in the countries from which our founding fathers migrated.

The Rule of Law does not mean the Rule of Law Enforcement. The Rule of Law means that we are governed by written laws that society has agreed upon INSTEAD of by kings, nobles, warlords and other powerful people who imposed their will on the populace. It is the rule of the WRITTEN law over the will of the individual with power.

We are heading fast toward becoming a police state as we give up our principles (such as guilty until proven innocent) because we are afraid and believe the police can protect us from everything. We are giving power to the police somewhat similiar to that of nobles, etc.

The police are becoming the powerful from whom we need the protection of the written law.
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Brian25
Conservative without all the Jesus
11:07 AM on 06/02/2010
I can't believe the number of people who support criminals. This guy confessed to a murder. There is no doubt in that. But the bleeding hearts are lining up help this guy out. Good for the court, score one for the victims.
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SF TKF
Cthulhu thinks you'd make a nice sandwich.
11:07 AM on 06/02/2010
How is it earth shattering to spell out that in order to invoke a right, you have to actually INVOKE it? You’ve always had to ask for a lawyer and it makes perfect sense that you have to state that you’re invoking your right not to speak to them or answer questions.
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CitizenT
11:47 AM on 06/02/2010
"And the Court has placed a substantial burden on suspects to invoke their rights with great precision. A number of lower courts applying the clear and unambiguous standard have been quite demanding, finding that statements such as "I think it's about time for me to stop talking" and "I think I would like to talk to a lawyer" are not clear invocations of the right to remain silent or the right to counsel."

That is the most disturbing part to me. If you don't say the right words in the exact order they can decide you don't really mean it. I don't like coddling prisoners, but I also don't like railroading people for not knowing the magic passwords.
02:25 PM on 06/02/2010
and don't forget the most magic word of all! I would like to invoke my right to silence...PLEASE!
02:18 PM on 06/02/2010
Because in order to invoke that RIGHT, you have to waive your privelege to remain silent by TALKING. And it had better be lawyerly when it comes out of your mouth. This is only about a millimeter away from saying that a person who SAYS that they are invoking their 5th amendment right to remain silent can then be assumed to have waived that right, because they spoke up to invoke it. Trust me, the rt-wing nutters on the Court are going to make an excuse to change the law to exactly that.
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DevonTexas
Eternal Optimism
10:57 AM on 06/02/2010
I think you're over-reaching in this argument to suggest Kagan had such influence. This court was intent on this decision regardless of Kagan's role and there's nothing to suggest she played a role in the court's decision.
06:12 PM on 06/12/2010
[i]"I think you're over-reaching in this argument to suggest Kagan had such influence. This court was intent on this decision regardless of Kagan's role and there's nothing to suggest she played a role in the court's decision." [/i]

It's not a question of how much influence she had right now. It's a question of her Amicus brief revealing her views, views which would wield a great deal of influence were she already on the court.

This is now the second time (the previous being a DOMA case) in which the Obama administration seems be filing Amicus briefs defending laws and practices that he previously claimed to oppose.
10:12 AM on 06/02/2010
What a distressing opinion especially after the recent Powell decision on Miranda.

What is it with Conservatives? They clamor all day that the government is bad and is incapable of doing anything correctly. But suddenly government employees, such as cops, prosecutors and judges, are virtually infallible when they are arresting, prosecuting and executing people. Giving the police more power to extract a confession from a suspect is a step closer to a police state. Where are the teabagger cries of tyranny now?
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Brian25
Conservative without all the Jesus
11:03 AM on 06/02/2010
They also believe that criminals belong in jail.
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CitizenT
11:48 AM on 06/02/2010
Yes, but they seem to think a criminal is anyone they can torture a confession out of.
09:30 AM on 06/02/2010
The president himself was negotiating away Miranda rights before this ruling and it is obvious that both Kagan and Obama share the same restricted view of people's rights.
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FirstGame72
The Sleep of Reason Produces Monsters
07:58 AM on 06/02/2010
"The Death of Miranda" has come as a direct result of 9/11. The powers that be simply can not have these prisoners speaking freely in a public forum.
Just go ask Seymour Hersh about blabbing about things in public the government doesn't like. Why do you think he stopped talking about those Abu Ghraib toture photos that were never released to the public?
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06:51 AM on 06/02/2010
In essence, "you have the right to remain silent unless you exercise it."

But the real matter here isn't "silence." It's ... ummm ... torturing prisoners. Oh, pardon me, "interrogating."

And if you don't speak the language well enough to say "just the right words ..." ¿Sabe?

It seems to me that in many ways we are forgetting, or at least not regarding, the principles that founded the basic freedoms that our country's founders put in place for all of us. As George Lucas put it, through his character of Queen Amadala: "So this is how freedom dies: to thunderous applause."
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DevonTexas
Eternal Optimism
10:58 AM on 06/02/2010
or "until" you exercise it.
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11:40 AM on 06/02/2010
Well, the perfectly obvious catch-22 here is the word "remain."

You have the right to "remain" silent.

Now, when (by definition) do you cease to "remain" silent? When you "say" anything at all. (Presumably the Miranda wording was aimed at someone who had not yet spoken a word.)

The moment you open your mouth, even to say that you wish to exercise your right to remain silent ... you obviously no longer "remain" silent.

But the Supreme Court of the United States, in its new role as "privy council" and de-facto lawmaker-supreme, knows that the King does not have to always be consistent in his royal edicts.

I think that we need to be =very= aware of just how rapidly, and in how many ways, the system of Government that we were taught growing up has changed. Congress may debate a five-thousand-page piece of legislation endlessly, and the President may or may not approve it ("all or nothing"), BUT ... the Supreme Court makes law. And, by declaring that it possesses the sovereign(!) right to "interpret" the Constitution, it de facto places itself above the very body of law that caused its own existence.

Tyranny will swiftly and inevitably follow.
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Puller58
Man of Mystery
05:53 AM on 06/02/2010
Hold on Sparky. This ruling is clarifies an old bugaboo that defense attornies have been milking for years. Kagan's role is simply another sign of her Establishment orientation.
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Acharn
03:07 AM on 06/02/2010
Hmmm. "Kagan did not have to enter the fray and take a position, but she decided to do so."

And you know this how? My understanding is that the Solicitor General takes orders from the President. Which probably means from his Chief of Staff. And, I suppose, from the Attorney General. It wouldn't surprise me to find out that the Speaker of the House and the Senate Majority Leader have some influence there, too. So what basis does Mr. Weisselberg have for making this assertion? Then, too, there's the point that has been made, that the arguments she presents to the Court do not represent her personal views, but rather her efforts to fulfill her duty to her client, the Government of the United States.
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AnotherTry
Tell me again why we can't be equal?
05:59 AM on 06/02/2010
Her duty is to uphold the constitution, not obey orders.
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Acharn
07:11 AM on 06/02/2010
So? She surely thinks that she IS upholding the constitution. The duty of a lawyer is to present every possible argument in favor of the client, including those that are contradictory. In normal criminal trials, the purpose is to make the prosecution actually PROVE its case, and often the evidence is not as clear-cut as CSI-Miami would like you to believe. In the case of appeals based on Constitutional points, her duty is to present the arguments she believes will best persuade the Court to find in favor of the government. In my post I was referring to the process of deciding what cases the Solicitor General chooses to support, and that's not clear at all.
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thinkingwomanmillstone
great, green, globs of greasy grimey GOPerspeak.
07:08 AM on 06/02/2010
I have to say that holding the state's attorney responsible for arguing the position of the state is similar to saying that those defense attorneys who represented the prisoners at Guantanamo are terrorist sympathizers. The system is set up so that both sides are supposed to represent their clients to the best of their ability. That said, I think this ruling on the Miranda warning is absolutely wrong.
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Eris23
Justice is in indefinite detention.
11:17 AM on 06/02/2010
Actually, no, it's not the same at all. The state is never a person on trial, and certainly wasn't here. If Kagan actually had feelings on the matter, she didn't have to go against them and she would face no repercussions aside from possibly losing her job. This has been a repeated criticism of Kagan, in that she is nothing but a careerist.

I have no confidence in Kagan due to the fact that she has never once been in a position to put her beliefs and judicial philosophy on the line in a way that matters. I was particularly alarmed by her agreement with Senator Graham regarding the misplaced and erroneous interpretation of "battlefield law" when it comes to the indefinite detention of people suspected of crimes. This latest revelation is of no help to redeeming her in that regard, and doesn't give me any confidence that she is suitable for the Supreme Court.
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01:57 AM on 06/02/2010
The really sad thing is that you don't have a right to be Mirandised. That’s not the point.
What you do have is the right to not incriminate yourself and that law is in place to preclude admissions extracted under torture. Ever hear of King Henry VIII?
Damn - you have a right not to incriminate yourself wither you were reminded about it or not - it’s still a right you have. Miranda is simply a cover given to the police to insure that they are not accused of extracting a torture confession. Miranda was never for the accused it was always for the police.
How hard was that?
03:11 AM on 06/02/2010
You are correct, Miranda is simply to remind you that you do not have to incriminate yourself, and you cannot be penalized for not answering questions. We all have the unalienable right to remain silent, whether we choose to keep our mouths shut or not doesn't change this fact. This law actually helps those who are being questioned, by allowing them to say they don't want to answer any questions, ending the interrogation.
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01:34 PM on 06/02/2010
You inderstand it. I understand it.
Are we are the only ones?
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shamanbart
01:45 AM on 06/02/2010
The Court has made another flawed decision because the Miranda warning doesn't state anything about time limits or more importantly, that you need to state clearly that you wish to remain silent. It only states you have the right to remain silent and have the right to an attorney, etc. Many people when in that situation wouldn't know that would stop an interrogation, though many know that refusing to speak until they see a lawyer would do it.

The Court missed an opportunity to improve the wording of the Miranda warning, and instead opted to encourage police interrogations of the unwitting.
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Acharn
03:15 AM on 06/02/2010
That's been the mission of the Right ever since the initial Court ruling in Miranda. I remember all the outcry about how nobody would ever confess again. Funny. Have you heard the name Burge? The Chicago police detective who got promoted to Regional Commander because he had such a fantastic record of getting convictions? At least 110 of his cases got a conviction because the suspect confessed -- after being tortured! Over twenty years! Some of them might even have been guilty of the crimes they were convicted of. Four went to death row. Conservatives say this is the way it should be. That it doesn't matter if the person is guilty or not, the police wouldn't accuse him/her if he/she wasn't guilty of SOMETHING!!!

I really cannot fathom why conservatives think it doesn't matter. Apparently they just believe that it can't happen to them, and it's a good thing to keep the underclasses down.
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IrisMozenter
10:14 AM on 06/02/2010
And of course Burge is now on trial himself, finally... Long overdue.
12:35 AM on 06/02/2010
I have question. How long do you need to stay silent before you are invoking your right, and the police should stop questioning? 3 hours? 10 minutes? 1 question? a few seconds? If a suspect is asked a question then doesn't answer for 10 seconds should the police leave? There it interpretation involved, and my idea and yours may differ, that leaves an irregular treatment of suspects based upon interrogators view of what silence is. This way, you are making a clear understanding that you are invoking your right to remain silent.
01:06 AM on 06/02/2010
If you do not declare that you are exerting your right to free speech can you be prosecuted for the words you say. A right is inherent to require an affirmitive act to claim a right is to deny the right exists inherent in a person. To supercede a right should require the opposite standard a clear affirmation you are waiving it.

A right exists inherently in us it isn't bestowed by the constitution it wasn't granted by us in the constitution. TO argue we must affirmitvely claim a right is judicial activism.
03:07 AM on 06/02/2010
The person being questioned has the right to not speak. It is simple, don't speak. Also, the right to a lawyer needs to be requested, they don't have lawyers in the interrogation rooms. In this case, the man chose to stay silent and the police kept asking questions, his right to stay silent was never in question, he chose to spoke and confessed. My point was, before this case, at what point do the police decide that he is invoking his right? They police; who have the right to free speech, can and should be able to ask questions as long as they like, assuming the suspects other rights are met.
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Eris23
Justice is in indefinite detention.
11:19 AM on 06/02/2010
The sure fire rule, if you are ever arrested, is to state that you will not talk to anyone until your attorney is present. Unfortunately, most people simply don't know this.