|
Dickerson v U.S.
530 U.S. 428 [2000]
Author: Sam Biers
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.
Defendant’s Argument:(pet/df)
Act effectively eliminates the strictures of Miranda, and
substitutes inadequate alternatives to determine voluntariness.
|
