“You have the right to remain silent” is a phrase most have heard, whether it be from a television show or personal experience. This phrase is from what is known as Miranda rights. Miranda rights are a centerpiece to the American legal system and arise out of the United States Constitution’s Fifth Amendment right against self-incrimination. But when exactly does an officer have to read an individual their Miranda rights? And what happens if an individual is not read their Miranda rights? The short and simple answer is that it depends. As is generally the case in law, there is no hard and fast rule, but instead, each case is fact sensitive. The Indiana Supreme Court recently dealt with this fact-sensitive analysis in State v. Ruiz;1 this is a case you should know and is the topic of this blog post.
In Ruiz, the Indiana Supreme Court was asked to rule on the issue of suppressing statements made by Defendant while in police custody. When the Court “suppresses” evidence, that means, generally, the evidence was obtained illegally. Suppression can be a remedy for a Defendant who was not read his Miranda Rights. This was the exact remedy the Defendant wanted to apply in the case at hand. The case began when the Defendant was taken by detectives to the police station for questioning. The detectives took Ruiz into a small, windowless room, which was located in a secure area of the police station. Furthermore, the officers questioned the defendant in an “accusatory” and hostile manner. Lastly, the officers outnumbered Defendant two to one for the large majority of the questioning and interrogation. This all occurred without Ruiz ever being read his Miranda rights.
At the hearing, the State wanted to use video footage of the interrogation. Ruiz, on the other hand, filed a motion to suppress the evidence because he was never read his Miranda rights. The trial court agreed with Ruiz and suppressed the video evidence.2 The State appealed the decision, and the Court of Appeals sided with the State, finding that the interrogation was not custodial. The Defendant appealed to the Supreme Court, and they sided with Defendant, reversing the Court of Appeals decision and upholding the trial court. In reaching this conclusion, the Indiana Supreme Court began by first discussing the standard for when Miranda applies, which is when a Defendant is under “custodial interrogation.” If a defendant is found to be under custodial interrogation, then he or she must be read their Miranda rights, if they are not, the statements made during the interrogation cannot be used to prove guilt.
The Court went on to note that “custody” under Miranda “occurs when two criteria are met. First, the person’s freedom of movement is curtailed to the degree associated with a formal arrest.” The second criterion a person undergoes “inherently coercive pressures.” In finding that these two criteria were met for the Defendant, the Court noted that the circumstances surrounding the interrogation (being in a small, windowless room; secured off from the rest of the police station; and being outnumbered by officers during the interrogation) were certainly sufficient to find that the first criterion is met. The Court found that a reasonable person, under those circumstances, would not feel free to leave. Moving to the second criterion, the Court found that the hostile and accusatory tone of the interrogation, coupled with the police lying to Defendant, were enough for the Court to find coercive pressures requiring Miranda warning. Finding both criteria met, the Supreme Court upheld the trial court’s decision to suppress the evidence.
This area of law is extremely technical, while also having the potential to completely change the course of your life. An individual who is unaware of their rights may have them violated without even knowing, leading to a negative result for you—like a conviction in this case. The importance of understanding the status of developments in the law is the key to avoiding criminal liability, as well as being an engaged citizen in our participatory system of government. This blog post on a key new case was written by attorneys at Dixon & Moseley, P.C. who handle criminal defense cases and appeals of criminal convictions throughout the state. This blog is written for educational purposes only. It is not intended as legal advice or a solicitation for services. It is an advertisement.