Johnson v. New Jersey
384 U.S. 719 (1966)
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Rule of Law:
The constitutional rules established in Escobedo v. Illinois and Miranda v. Arizona, which concern the rights of suspects during custodial interrogation, are not applied retroactively. These rules apply only to trials that commenced after the dates on which those respective decisions were announced.
Facts:
- In January 1958, Stanley Cassidy was taken into custody for felony murder in Camden, New Jersey.
- Police interrogated Cassidy for several hours, during which he confessed. Before questioning, an officer warned him that his statements must be voluntary and could be used against him, but did not inform him of a right to counsel.
- Cassidy later alleged that he repeatedly asked for a lawyer during the interrogation but was denied.
- Also in January 1958, Neil Johnson was arrested for the same crime, driven 80 miles to Camden, and interrogated by police.
- Johnson received a similar warning to Cassidy's, but was not advised of a right to counsel, and he subsequently confessed.
- Johnson later claimed he also asked for an attorney multiple times and was refused, and that police prevented his family from contacting him.
Procedural Posture:
- Johnson and Cassidy were jointly tried for felony murder in a New Jersey state trial court.
- The trial judge found their confessions voluntary and admitted them into evidence.
- A jury found both petitioners guilty of first-degree murder, and they were sentenced to death.
- The Supreme Court of New Jersey, the state's highest court, affirmed their convictions on direct appeal.
- After their convictions became final, petitioners engaged in numerous unsuccessful collateral attacks in state and federal courts.
- Following the Supreme Court's decision in Escobedo v. Illinois, petitioners filed another post-conviction relief application, arguing their confessions were inadmissible under the new rule.
- The Supreme Court of New Jersey denied relief, holding that Escobedo did not apply retroactively to convictions that were already final.
- The U.S. Supreme Court granted certiorari to review the question of retroactivity.
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Issue:
Do the constitutional rules established in Escobedo v. Illinois and Miranda v. Arizona regarding custodial interrogation apply retroactively to convictions that became final before those decisions were rendered?
Opinions:
Majority - Chief Justice Warren
No. The rules established in Escobedo and Miranda do not apply retroactively. The Escobedo rule applies only to trials that began after June 22, 1964, and the Miranda rule applies only to trials that began after June 13, 1966. The Court's decision rests on a three-factor analysis for retroactivity: the purpose of the new standards, the reliance placed on prior decisions, and the effect of retroactive application on the administration of justice. The purpose of Escobedo and Miranda is primarily to safeguard the privilege against self-incrimination, and while they guard against unreliable statements, existing voluntariness tests already protect defendants in prior cases. Furthermore, law enforcement agencies had reasonably relied on previous Supreme Court decisions that did not mandate such warnings. Applying the rules retroactively would severely disrupt the administration of justice by requiring retrials or the release of numerous prisoners convicted under previously accepted constitutional standards.
Dissenting - Justice Black
Yes. The petitioners should be entitled to the full protections of the Fifth and Sixth Amendments as interpreted in Escobedo and Miranda. The dissent, referencing the dissenting opinion in Linkletter v. Walker, argues that constitutional rights should not be applied prospectively. If a conviction was obtained in a manner that the Court has now deemed unconstitutional, the defendant should receive the benefit of that ruling, regardless of the timing of their trial.
Analysis:
This decision is significant for establishing the principle of non-retroactivity for major, prophylactic rules of criminal procedure. By limiting the application of Escobedo and Miranda to future trials, the Court prevented the invalidation of countless convictions obtained in reliance on prior law. The case solidifies the three-part balancing test for determining retroactivity, weighing the rule's purpose against reliance and administrative burden. This approach allows the Court to reform constitutional criminal procedure without creating systemic chaos, effectively drawing a line between past and future legal standards.
