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Geoffrey R. Stone

Geoffrey R. Stone

Posted: May 17, 2010 08:56 PM

Missing the Point: Terrorism and Miranda

What's Your Reaction:

There's been quite a fuss lately about whether government officials should have to give Miranda warnings to persons arrested for alleged terrorist acts. Attorney General Eric Holder has called upon Congress to enact legislation that would authorize government investigators not to give Miranda warnings in such circumstances.

The primary concern seems to be that if a person in custody receives Miranda warnings, he will be less likely to speak with his interrogators and the government will therefore lose potentially valuable intelligence information that might help combat terrorist networks and prevent future attacks. Although no one seems to have noticed, this concern is completely misplaced.

To understand why this is so, we need to go back to basics. The Fifth Amendment protects the privilege against compelled self-incrimination. The privilege prohibits the government from using any statement that it has coerced from an individual against him in a criminal trial.

In simplest form, this means that the government may not punish a criminal defendant for refusing to take the stand and incriminate himself at his own trial. But it goes beyond that. As the Supreme Court long ago recognized, the same principle must also govern pre-trial interrogations. That is, if the government cannot constitutionally coerce a defendant to incriminate himself at trial, it follows that it cannot constitutionally use at trial a confession that it has coerced from him at an earlier stage of the proceedings. For example, the privilege prohibits the government from using against a criminal defendant a confession that it beat out of him prior to trial.

It is often difficult to know, however, when a confession was given voluntarily and when it was the product of coercion. To mitigate the "inherently coercive" atmosphere of custodial interrogations, the Supreme Court held almost half-a-century ago in Miranda v. Arizona that any statement obtained by government interrogators from a person being held in custody must be presumed to be involuntary and therefore inadmissible in evidence against him at trial, unless the interrogators informed him prior to the interrogation that he has a right to remain silent, that anything he said can and will be used against him, and that he has a right to the assistance of an attorney. Only if the individual knowingly waives those rights can a statement made in the course of a custodial interrogation be used against him at trial.

It is certainly true that the giving of Miranda warnings reduces the likelihood that an individual subjected to custodial interrogation will make an incriminating statement. (It is important to note, however, that an incriminating statement is not the same thing as a confession, and that innocent people often make incriminating statements. For example, if you are arrested for murder, you might admit that you knew the victim, that you own a gun, that you were in town on the day of the murder, and that you had recently had a quarrel with the victim. All of those facts are incriminating and can be damaging to you at trial, but they might well be true even though you are innocent of the murder. Thus, even innocent suspects must be careful about making self-incriminating statements.)

The key point, though -- the point that has consistently been overlooked in the public debate over this issue -- is that government interrogators are under no constitutional obligation to give Miranda warnings - even when they interrogate a suspect in custody. This is so because the privilege against compelled self-incrimination protects individuals not against being compelled to make self-incriminating statements, but against the use of such statements against them at trial.

The Supreme Court made this perfectly clear in its 2003 decision in Chavez v Martinez, in which the Court held that the failure to give a suspect Miranda warnings is not a violation of the privilege against compelled self-incrimination, even if the suspect makes incriminating statements, if the statements are not used against the defendant at trial.

Indeed, in Martinez the situation was even worse. The police officers not only failed to give the suspect Miranda warnings, but also withheld medical treatment to him, even though he had been shot, in order to get him to confess. Even in those circumstances, the Court (rightly, in my view) held that there had been no violation of the privilege against compelled self-incrimination, because the statements were never used against him at trial. The privilege is violated, in other words, only when the coerced statement is use in court to prove the coerced individual's guilt.

This is all directly relevant to the interrogation of persons suspected of terrorist activity. The primary objection to giving such individuals Miranda warnings is not that they will not incriminate themselves. That is true for all suspects, including rapists, assassins and mass murders. Rather, the very specific and distinctive concern in the context of terrorism investigations is that if the suspect clams up the government might be denied critical information that might help it prevent future terrorist attacks. That is certainly an important concern.

But if the government wants to question such a suspect in order to learn about his training, the people he knows, the organizations with which he is associated, or whether he has inside information about other terrorist plots, it is completely free to do so without giving him Miranda warnings. And if the suspect then makes statements that reveal such information, the government is completely free to use that information to further its investigations and to prosecute any other individuals the suspect inculpates.

Of course, if the government does not give the suspect Miranda warnings, it cannot use his presumptively coerced statements against him in a subsequent criminal proceeding. But the government is still completely free to prosecute and convict him based on other evidence of his guilt.

Thus, it simply is not true that the giving of Miranda warnings interferes with the government's ability to obtain essential intelligence information from suspects who have been arrested for alleged terrorist activity. There is no need for special legislation to empower the government to do what it is already able to do.

What the government would gain from such legislation is not a greater effectiveness in preventing future terrorist attacks, but the ability to use coerced confessions against criminal defendants in violation of the privilege against compelled self-incrimination. This, the Constitution does not allow.

 
 
 
 
 
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10:33 AM on 05/19/2010
I believe the primary reason why the government does not want to be bound by Miranda in these cases is because of the principle known as the "fruit of the poisonous tree". This principle works to exclude not only the confession itself, but all evidence which is derived or which is uncovered by virtue of information obtained from the confession. Thus, if a suspect tells the cops that the gun is "located in the duffel bag", the gun can not be used as evidence, forensic evidence establishing the gun as the murder weapon can not be used, etc....

In this case, we can probably assume that the authorities have sufficient evidence without any statements from the accused to establish attempted murder. However, they probably do not have sufficient evidence to establish a criminal conspiracy to commit acts of terrorism against the US... a crime carrying much harsher penalties. Any statements made by the accused and any evidence derived from those statements would be excluded. Thus, if they follow up on leads revealed by the confession which points to another individual, a paper trail of money transfers from that individual to the accused could not be used at the trial of the accused.

Now, with that said, I want to state that I believe there should not be any exception to the Miranda rule merely because the suspect is considered to be a terrorist. My purpose is to make sure that we fully understand the consequences of such a decision.
01:05 AM on 05/23/2010
This is actually wrong. Fruit of the poisonous tree does not apply to Miranda violations. It applies to illegal searches and seizures.
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checkmoot
We have met the enemy and he is us.
03:58 PM on 05/18/2010
I was thinking of those "Christian" militiamen arrested for planning mass killings of police officers. No complaint about them getting Mirandized. It seems that the dividing line is religion. If you are a Moslem you are a terrorist with no rights. If you are a Christian like McVeigh, who killed hundreds when he bombed the Fed Building in Oklahoma, you are not a terrorist. Tough times to be an American Muslim.
01:32 PM on 05/18/2010
so since we are so worried about letting terrorists get use of our courts then what happens when lets say a muslim person from iran gets caught trying to blow up a couple of schools. then at trial his lawyer wants a change of venue, then the jury is picked but the lawyer wants case dropped as all the people on the jury are american citisens and none are muslim. is this a jury of his peers.
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TexasDem0
USMC Vietnam combat vet
12:18 PM on 05/18/2010
Denying Miranda Rights for someone accused of terrorism is a victory for the terrorists.

Their goal is to bring down our way of life. This is one step in that direction. Once it is accepted that someone who is merely accused of a particular crime can have his rights suspended, the next step is to include another type of accusation, than another, and another. As we approach an absolutist government where civil rights are subservient to government control, as initiated by accusation, the terrorists win. Our way of life becomes more like theirs.
12:09 PM on 05/18/2010
As usual, Professor Stone makes his points with documented facts and scrupulous logic. Too bad that these things don't seem to count in any political debate anymore.
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molonlabe
I rarely go full Wookie but own a whole suit.
11:38 AM on 05/18/2010
I'm curious.....how many of those who support alleged terrorists being read Miranda, also oppose the recent push to close the "Terror Gap":

http://www.huffingtonpost.com/2010/05/15/nra-members-disagree-with_n_577491.html?show_comment_id=0#comment_0

http://www.huffingtonpost.com/cliff-schecter/its-pretty-simple-terrori_b_566177.html

http://www.huffingtonpost.com/2010/05/04/nyc-mayor-bloomberg-outra_n_563337.html


Seems to be a lot of hypocrisy here. I'm noticing that many of those who support alleged terrorists Miranda rights seem to backpedal when addressing the issue of infringing upon US citizen's 2nd Amendment rights w/o due process.

Can't have it both ways. Alleged is alleged, even when talking about those scary, icky guns.
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Weezbo Logan
04:39 PM on 05/18/2010
Yep. I'm with you there. That's why I support Mirandizing accused criminals in the US, be they citizens or illegal; pedophiles, thieves, or terrorists; or any other classification of criminal. And, at the same time, I support the rights of gun owners to keep their firearms regardless of whatever due process circumventing watch list or no fly list they happen to be on. Get the conviction, then abolish the rights, not the other way around.
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molonlabe
I rarely go full Wookie but own a whole suit.
08:38 AM on 05/19/2010
Right on.
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10:49 AM on 05/18/2010
the privilege imo is broader. you cannot compel testimony once the 5th is invoked in a civil trial, a civil deposition or civil discovery for example. a debtor can invoke the 5th in a debtors examination as well.
10:04 AM on 05/18/2010
I think the calculation law enforcement has to make is quite straightforward: if you value the information the suspect can provide more than successfully convicting him in open court, don't read him Miranda.
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ThatsTheTheWayItIs
religion, ideology, partisanship are delusional
09:42 AM on 05/18/2010
Miranda was a Latino railroaded by the law in Arizona.

True, right? An interesting connection of current neocon Crusades.
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ThatsTheTheWayItIs
religion, ideology, partisanship are delusional
09:39 AM on 05/18/2010
We overstate the importance of the Miranda decision.
It came in 1966; we had full Fifth Amendment rights long before then.
Criminals knew they had a right to an attorney, from old gangster films.
Miranda just gave us the right to know what our rights are.

Ironically, now that Miranda exists, we don't need it.
Everyone who watches TV knows they "have a right to remain silent, right to an attorney".
As if terrorists won't know their rights if we don't tell them. That's what a joke denying Miranda is.
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straightuptalker
What ever happened to common sense?
07:33 AM on 05/18/2010
Miranda Rights for terrorists? Since when should our enemies be granted the same rights as Americans? The Constitution is here to protect the rights of American citizens...not traitors, terrorists or spies who aid and collude with the enemy. It's true...we're too soft on this issue and the bleeding-heart liberals have imposed their errant opinions of what is cruel and unusual punishment, so they've turned to coddling and protecting heartless, fanatical and maniacal enemies who blow up their own people, along with our own. Everybody including our elected politicians, military chiefs and legal experts have done an "about face" on this issue and we no longer have the guts or desire to intimidate or strike fear in the hearts of our enemies. Poor old Ike must be churning in his grave.
08:33 AM on 05/18/2010
The Times Square wannabe bomber was an American citizen.
09:08 AM on 05/18/2010
This is also why prisoners are supposed to have rights, though they usually get trampled and very few people care, since the public at large presumes prisoners to be guilty. But the truth is, while we have a very good legal system, it's not perfect, and it still puts some innocent people in jail. Since some of these people are innocent, we have to afford the general population some basic rights to be sure that we don't completely destroy an innocent person who gets sent to jail. While no longer presumed innocent, the possibility of their innocence is why they still need to be afforded some basic rights.

So basically, stop pretending EVERYONE accused of a specific crime is guilty. They aren't. This is why we have tiers of rights for accused and convicted criminals. By the time we reach convictions, I'd like to think most truly are guilty. This is why they get so few rights, and why it's (supposed to be) so hard to convict someone. Those who are simply accused are often innocent, which is why we give them so many rights to exercise to protect themselves before and at trial.
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10:57 AM on 05/18/2010
the right is not limited to citizens. the framers knew the word citizen and used it in other provisions in the constitution. the 6th amendment says the accused. read it. if they meant citizens only they would have said so.
09:08 AM on 05/18/2010
Miranda rights for people ACCUSED OF terrorism. Those two words make a huge, huge, difference. What if you were accused of murder tomorrow, then denied legal recourse because everyone started calling you a murderer? Just suit up and go to jail, no trial, no lawyer, nothing. That's what we do to people accused of terrorism, some of them actually innocent, just as you would be in this hypothetical scenario. This is why we have these rights in the first place. They exist to protect the innocent. That's why you have the right a to trial, a lawyer, and not to make incriminating statements. The first two are self explanatory, but the last may not be. An incriminating statement can be made by an innocent person. If you happen to mention that you own a gun, knew the victim of a murder, and happened to be in town that day, you've made an incriminating set of statements, even if you did not commit the crime. This is why we have the fifth amendment. Do criminals use it too? Of course they do. But it's there to protect the innocent, and you have to allow everyone to use it, or it loses its ability to protect the innocent.
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Pandaforum
04:58 AM on 05/18/2010
i think you're missing the point. holder is making a political statemment. obama looks like he's coddling terroists so the obama regime is making noises to pretend he isn't. there will be no change in miranda rights. enemy combatants aren't entitled to miranda rights or a lawyer for that matter. the real issue is whether traitors have miranda rights? past precendence says no. fdr didn' cut traitors any slack. he had them stood up against the wall and shot. of course now days traitors are worshiped by the left and given plush jobs in the government.
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11:28 AM on 05/18/2010
Let's see. When Clinton was President there was a terror attack on the World Trade Center and the terrorists were tried in court and now are in prison. When Bush was President, the worst USA terror attack of all time happenned under his watch, and Bin Laden was never apprehended, but Bush did invade Iraq. (Too bad Bush skipped geography when he was in school, because most of the terrorists were from Saudi.) Terrorists are still trying to get us, but no one in Americans has been killed (unlike the 3,000 that died under Bush) and you think Obama is soft on terror? Sounds like Bush was a complete idiot on terror, because his record is the worst. Bush had lots of warning. And it wasn't like 9/11 was the first terror attack against America, but it sure caught Bush by surprise.
TOOO
Warning: Rabid Monty Python fan!
01:09 AM on 05/18/2010
I think the theory behind denying Miranda rights to terrorists is that they should be treated like Enemy Combatants - Prisoners of War, if you like. This is a huge mistake. It gives legitimacy to terrorist organizations and a propaganda victory.

Terrorist organizations are criminal organizations - not foreign armies. By giving them Miranda rights, they remain criminals, not Holy Warriors.
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MrsGreebers
10:59 AM on 05/18/2010
The theory is not so nuances as your thoughtful post suggests. The theory is HE'S A TERRORIST WE KNOW HE'S A TERRORIST!
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11:01 AM on 05/18/2010
it is also a bad precedent when my front yard can be part of a battleground even if there has been no violence within 100 miles of it.
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Dave24
Without God, life is everything.
12:59 AM on 05/18/2010
When rights are deemed "flexible," as Holder called it, they cease to be rights.
11:39 PM on 05/17/2010
I agree, and I think John McCain should be seen accused of being soft on terrorism for suggesting that the Times Square terror suspect should not be read his Miranda rights. That would only make it harder for prosecuters to convict the suspect and put him in prison.