Adequacy of Miranda Warnings And US Supreme Court Jurisdiction
FLORIDA V. POWELL : United States Supreme Court decided February 23, 2010
559 U.S.____, 130 S.Ct. 1195 (2010)
Issue : Whether the U.S. Supreme Court has jurisdiction to review a decision by a State’s highest Court when that Court is interpreting the U.S. Constitution.
Held : The U.S. Supreme Court will review a State’s highest Court’s decision interpreting the U.S. Constitution if the decision does not rest on a state law ground that is independent of the federal question and adequate to support the judgment.
Issue : Whether the Miranda warnings given by Florida police were sufficient to warn the defendant that he had the right to an attorney throughout the questioning by police.
Held : The Miranda warning were sufficient to inform defendant that he had the right to an attorney before and during the questioning as long as they convey the basic information set out in Miranda and the U.S. Supreme Court declined to specify and rigid formulation to Miranda warnings.
In 2004 the Tampa Florida police entered an apartment rented by the defendant’s girlfriend. They spotted the defendant coming from a bedroom and the officer searched the room, finding a handgun under the bed. They arrested the defendant and before questioning him read him this standard consent and release form:
“you have the right to remain silent. If you give up the right to remain silent, anything you say can be used against you in court. You have the right to talk to a lawyer before answering any of our questions. If you cannot afford to hire a lawyer, one will be appointed for you without cost and before any questioning period you have the right to use any of these rights at any time you want during this interview .”
The defendant then admitted that he owned the handgun, and was later charged with possession of a weapon. He moved to suppress his statements arguing that the Miranda warnings were deficient because they did not adequately conveyed his right to the presence of an attorney during questioning.
The case wended its way to the Florida Supreme Court where the following question was certified to the court: “does the failure to provide express advice of the right to the presence of counsel during questioning vitiate Miranda warnings which advised of both the right to talk to a lawyer before questioning and the right to use the right to consult a lawyer at any time during questioning?”
The United States Supreme Court Jurisdictional Issue :
The United States Supreme Court will not review questions of federal law decided by a state court if the decision rests on a state law ground that is independent of the federal question that is adequate to support the judgment. State courts should be left free and unfettered by the US Supreme Court in interpreting their own state constitution. If the state court decision indicates clearly and expressly that it is based on separate, adequate, and independent grounds the United States Supreme Court will not review the decision.
The Supreme Court held in this case that it had jurisdiction because the Florida Supreme Court treated state and federal law as interchangeable and interwoven and that court at no point expressly asserted that state law sources gave the defendant rights distinct from, or broader than, those delineated in Miranda .
The Adequacy Of Miranda Warnings:
The issue in this case was whether the defendant was clearly informed that he had the right to consult with a lawyer and have the lawyer with him during questioning.
The US Supreme Court stated that the issue before them was simply whether the warnings recently convey to a suspect his rights as required by Miranda . The Court relied heavily on two previous cases: Duckworth v. Eagan , 492 U.S. 195 (1989) and California v. Prysock , 453 U.S. 355 (1981) both concerned a suspect’s entitlement to adequate notification of the right to appointed counsel.
The Florida Supreme Court had found that the warnings were misleading because it believed the temporal language – that the defendant could talk to a lawyer before answering any of the questions – suggested that defendant can consult with an attorney only before the questioning began.
The US Supreme Court disagreed stating that the term “before” merely conveyed the right to an attorney became effective before he answered any questions at all. They found that nothing in the words used indicated that counsel’s presence would be restricted after the questioning commenced.
Defendants attorney had argued that most jurisdictions throughout the nation expressly advised suspects of the right to have counsel present both before and during interrogation and that anything less would tempt law enforcement to circumnavigate Miranda by amending their warnings to introduce ambiguity. The US Supreme Court noted that law enforcement agencies have little reason to assume the litigation risk of experimenting with novel Miranda formulations and that it is desirable police practice to state warnings with maximum clarity.
Ultimately, the Supreme Court declined to state any precise formulation necessary to meet the required Miranda warnings.