Rhode Island v. Innis
446 U.S. 291 (1980)
Rule of Law:
For Miranda purposes, interrogation is not only express questioning but also its functional equivalent, which includes any words or actions by police that they should know are reasonably likely to elicit an incriminating response from the suspect.
Facts:
- John Mulvaney, a taxi driver, was discovered dead from a shotgun blast to the head.
- Shortly after, another taxi driver, Gerald Aubin, reported being robbed by a man with a sawed-off shotgun.
- Aubin identified a photograph of Thomas Innis as his assailant.
- Police located and arrested Innis, who was unarmed at the time.
- After being read his Miranda rights multiple times by different officers, Innis stated that he understood his rights and wanted to speak with a lawyer.
- Three police officers were assigned to transport Innis to the central police station in a caged wagon.
- During the transport, two of the officers engaged in a conversation, expressing concern that a child from a nearby school for handicapped children might find the missing shotgun and get hurt.
- Innis interrupted the officers' conversation and told them to turn the car around so he could show them the location of the gun.
Procedural Posture:
- Thomas Innis was charged by a grand jury with kidnaping, robbery, and murder.
- Innis filed a pretrial motion in the trial court to suppress the shotgun and his statements regarding its location.
- The trial court denied the motion, finding Innis had intelligently waived his rights, and the evidence was admitted at trial.
- A jury found Innis guilty on all counts.
- Innis, as appellant, appealed the conviction to the Supreme Court of Rhode Island.
- The Rhode Island Supreme Court, the state's highest court, set aside the conviction, holding that the police had interrogated Innis in violation of his Miranda rights.
- The State of Rhode Island, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court to review the decision.
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Issue:
Does a conversation between police officers in the presence of a suspect, concerning a danger posed by a hidden weapon, constitute 'interrogation' under Miranda v. Arizona after the suspect has invoked his right to counsel?
Opinions:
Majority - Mr. Justice Stewart
No, the conversation did not constitute interrogation. Interrogation under Miranda includes express questioning and its 'functional equivalent'—any words or actions by police that they should know are reasonably likely to elicit an incriminating response. The officers' conversation was a brief dialogue not directed at Innis, and there was no evidence to suggest they were aware that Innis was peculiarly susceptible to an appeal to his conscience concerning the safety of handicapped children. The conversation was not a lengthy harangue or particularly evocative. While the comments may have constituted 'subtle compulsion,' they did not rise to the level of interrogation because the officers should not have known their remarks were reasonably likely to elicit an incriminating response.
Concurring - Mr. Chief Justice Burger
I concur in the judgment. The new test established by the majority may introduce uncertainty, as it requires police officers to evaluate the suggestibility and susceptibility of an accused. Few officers are competent to make such a psychological evaluation in the brief time available, which may create confusion for trial judges applying this new standard.
Concurring - Mr. Justice White
I concur. Given the Court's precedent in Brewer v. Williams, I join the opinion of the Court in this case, although I would have preferred to reverse based on my dissenting opinion in Brewer.
Dissenting - Mr. Justice Marshall
Yes, this was interrogation. While I agree with the Court's definition of interrogation, its application here is incorrect. The officers' conversation was a powerful appeal to the conscience of any suspect, asserting that a helpless, handicapped child could be killed if the weapon was not found. This is a classic interrogation technique designed to elicit a response. The officers knew Innis would hear their conversation and are responsible for the psychological pressure they created.
Dissenting - Mr. Justice Stevens
Yes, this was interrogation. The majority's test is too narrow; the proper definition of interrogation should include any police statement or conduct that would appear to a reasonable person in the suspect's position to call for a response. The officers' conversation, which involved emotionally charged words about a 'little girl' getting hurt, was designed to elicit a response. The Court’s new test creates an incentive for police to use psychological ploys to circumvent a suspect’s invocation of their rights.
Analysis:
This case is significant for defining 'interrogation' under Miranda to include not just express questioning but also its 'functional equivalent.' The Court established an objective test focusing on the foreseeability of a suspect's response from a reasonable police officer's perspective. This shifts the analysis away from the subjective intent of the officers, though intent remains a relevant factor. The decision clarifies the scope of Miranda protections but has also been criticized for creating a difficult standard for police to apply and potentially permitting subtle psychological coercion that does not technically qualify as interrogation.
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