Doyle v. Ohio
426 U.S. 610 (1976)
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Rule of Law:
Using a defendant's silence, maintained after receiving Miranda warnings, for impeachment purposes at trial is a violation of the Due Process Clause of the Fourteenth Amendment.
Facts:
- William Bonnell, a police informant, arranged to sell 10 pounds of marihuana to petitioners Jefferson Doyle and Richard Wood.
- Narcotics agents provided Bonnell with $1,320, which was $430 less than the agreed-upon price of $1,750.
- Bonnell met Doyle and Wood, and the transaction took place in a parking lot in New Philadelphia, Ohio, while under police surveillance.
- After the exchange, Doyle and Wood realized they had been shorted on the payment and began driving around looking for Bonnell.
- Police officers, directed by the narcotics agents, stopped Doyle and Wood's car.
- Agent Kenneth Beamer arrived at the scene, arrested both men, and immediately gave them Miranda warnings.
- Doyle and Wood remained silent regarding their version of events following their arrest and Miranda warnings.
- A subsequent search of Doyle's car, authorized by a warrant, uncovered the $1,320 in cash.
Procedural Posture:
- Petitioners Doyle and Wood were charged with selling marihuana in the Common Pleas Court of Tuscarawas County, Ohio, a state trial court.
- They were convicted in separate trials, during which the prosecutor cross-examined each of them about their post-arrest silence.
- The trial court overruled defense counsel's objections to this line of questioning.
- Both Doyle and Wood, as appellants, appealed their convictions to the Ohio Court of Appeals, Fifth District, an intermediate appellate court.
- The Court of Appeals affirmed the convictions, holding that the cross-examination was permissible to challenge the defendants' credibility.
- The Supreme Court of Ohio, the state's highest court, denied further review.
- The United States Supreme Court granted certiorari to resolve the constitutional question.
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Issue:
Does the use of a defendant's post-arrest silence, after receiving Miranda warnings, to impeach their exculpatory testimony at trial violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Powell
Yes. The use of a defendant's post-arrest silence following Miranda warnings to impeach an exculpatory story told at trial is fundamentally unfair and violates the Due Process Clause. The Miranda warnings carry an implicit assurance that silence will carry no penalty. An arrestee's silence in the wake of these warnings is 'insolubly ambiguous,' as it may be nothing more than the exercise of the very rights the police are required to explain. Therefore, allowing a prosecutor to use this silence to imply that the defendant's later testimony is a recent fabrication would penalize the defendant for exercising their constitutional rights.
Dissenting - Justice Stevens
No. The use of a defendant's post-arrest silence for impeachment purposes does not violate due process. The Miranda warning is not a deceptive promise that silence will not be used for any purpose; it is an advisement of rights. A defendant's silence in the face of circumstances that would naturally prompt an innocent person to speak (such as being framed) is highly probative and inconsistent with a later exculpatory story. The jury should be permitted to consider this inconsistency when evaluating the defendant's credibility, and there is no constitutional bar to using prior inconsistent silence for impeachment, as distinct from using it as substantive evidence of guilt.
Analysis:
This decision establishes a crucial bright-line rule protecting a defendant's Fifth Amendment rights as outlined in Miranda. By forbidding the use of post-Miranda silence for impeachment, the Court prevents the government from turning the exercise of a constitutional right into a tool for the prosecution. This reinforces the value of the Miranda warnings, ensuring that the right to remain silent is not a trap for the unwary. The ruling significantly limits a prosecutor's ability to cross-examine a defendant who testifies, forcing the prosecution to challenge the credibility of an exculpatory story without reference to the defendant's initial silence.
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