Federal Power to Regulate Private Conduct under the 14th – Interpretive Power:
Relevant Facts: Petitioner Dickerson was indicted for bank robbery, conspiracy to commit bank robbery, and using a firearm in the course of committing a crime of violence. Before trial, Dickerson moved to suppress a statement he had made at a Federal Bureau of Investigation field office, on the grounds that he had not received “Miranda warnings” before being interrogated. Two years after Miranda was decided, Congress enacted § 3501.
Legal Issue(s): Whether the Miranda decision, being a constitutional decision of this Court, may be overruled by a legislative Act of Congress?
Court’s Holding: No
Procedure: Defendant was charged with conspiracy to commit bank robbery and other offenses. D. ct. granted suppression of confession. Govt motioned for reconsideration; denied, govt then appealed. Ct. of App reversed and remanded. S. Ct. Reversed
Law or Rule(s): The Congress has supervisory authority over the federal cts, and may use that authority to prescribe rules of evidence and procedures that are not required by the Constitution and are therefore binding. Congress may not legislatively supercede out decisions interpreting and applying the Constitution.
Court Rationale: In Miranda the ct opined that the Constitution would not preclude legilative solutions that differed from the warning, but which were at least as effective in apprising accused persons of their right of silence. The additional remedies within the Act are insufficient to meet the constitutional minimums. The Act abandons the requirement of pre-interrogation warnings. The Act or the test thereunder to determine voluntariness is more difficult than Miranda for officers to conform to, and for cts. to apply in a consistent manner. Congress may not legislatively supercede judicial decisions that are in line with the Constitution without violating the Constitution itself.
Plaintiff’s Argument:(resp US) The act complies with the requirement that a legislative alternative to Miranda has to be equally as effective in preventing coerced confessions.