United States v. Mandujano
425 U.S. 564 (1976)
Rule of Law:
The Fifth Amendment does not require full Miranda warnings for a grand jury witness, even if they are a target of the investigation, and the failure to provide such warnings does not require the suppression of the witness's false testimony in a subsequent prosecution for perjury.
Facts:
- In March 1973, an undercover narcotics agent met with Roy Mandujano, a bartender, based on information that Mandujano was involved in drug trafficking.
- During their meeting, Mandujano agreed to procure heroin for the agent and accepted $650 from the agent for the purchase.
- Mandujano left with the money but returned an hour later without the heroin and refunded the agent's money.
- Mandujano told the agent to call him later to arrange the transaction, but he was subsequently unreachable.
- Approximately six weeks later, Mandujano was subpoenaed to testify before a federal grand jury investigating local narcotics traffic.
- Before testifying, the prosecutor advised Mandujano of his Fifth Amendment privilege against self-incrimination, his duty to testify truthfully to avoid perjury, and his right to consult with a lawyer outside the grand jury room.
- During his sworn testimony, Mandujano denied having discussed the sale of heroin with anyone within the last year and denied ever agreeing to procure heroin for anyone.
Procedural Posture:
- Roy Mandujano was indicted by a federal grand jury on charges of attempting to distribute heroin and making a false material declaration to the grand jury (perjury).
- In the U.S. District Court for the Western District of Texas, the trial court of first instance, Mandujano moved to suppress his grand jury testimony.
- The District Court granted the motion, finding that Mandujano was a 'putative defendant' and thus was entitled to full Miranda warnings before his testimony.
- The Government, as appellant, appealed the suppression order to the U.S. Court of Appeals for the Fifth Circuit, an intermediate appellate court.
- The Court of Appeals affirmed the District Court's ruling, holding that the failure to give Miranda warnings required suppression of all of Mandujano's testimony.
- The United States, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court to review the judgment of the Court of Appeals.
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Issue:
Does the failure to provide full Miranda warnings to a grand jury witness who is a target of the investigation require the suppression of the witness's false testimony in a subsequent prosecution for perjury?
Opinions:
Majority - Burger, C.J.
No. The failure to provide Miranda warnings to a grand jury witness does not require the suppression of perjured testimony in a subsequent perjury prosecution. This opinion, which announced the judgment of the Court, is a plurality opinion. The Court reasoned that Miranda warnings were created to counteract the coercive atmosphere of custodial police interrogation, a setting fundamentally different from a grand jury proceeding. A grand jury witness is not in custody and has a legal obligation to testify, subject only to a valid claim of the Fifth Amendment privilege against self-incrimination. Unlike a suspect in custody who has an absolute right to silence, a grand jury witness must answer all questions unless the answers are self-incriminating. Therefore, providing a full Miranda warning, including the right to remain silent, would be incorrect and misleading in the grand jury context. The Fifth Amendment privilege protects against compelled self-incrimination; it does not confer a license to commit perjury.
Concurring - Brennan, J.
No. Concurring in the judgment, Justice Brennan agreed that the Fifth Amendment provides no privilege to commit perjury. However, he argued that the plurality's view of the Fifth Amendment was too narrow. In his view, when the government has probable cause to suspect an individual of a crime (a 'putative defendant'), it may not compel that person to testify before a grand jury about the crime without first securing an intentional and knowing waiver of their rights. This would require warning the witness that they are a target of the investigation, of their right to refuse to answer incriminating questions, and of their right to counsel, including appointed counsel for the indigent, with whom they could consult outside the grand jury room. Justice Brennan expressed concern that failing to provide such safeguards allows prosecutors to subvert the adversary system by using the grand jury for pre-indictment discovery against a suspect.
Concurring - Stewart, J.
No. Concurring in the judgment, Justice Stewart argued for a much narrower holding. The Fifth Amendment privilege against compulsory self-incrimination provides no protection for the commission of perjury. Because Mandujano's grand jury testimony was only relevant to his prosecution for perjury, and there was no claim of prosecutorial misconduct rising to the level of a due process violation, the Court needed only to hold that lying under oath is not a constitutionally protected act. The judgment should be reversed on this simple basis without reaching the broader questions about Miranda warnings or the rights of grand jury witnesses.
Analysis:
This decision establishes a clear distinction between the coercive environment of custodial police interrogation, where Miranda warnings are required, and the formal judicial setting of a grand jury. By holding that Miranda does not apply to grand jury witnesses, even those who are targets of an investigation, the Court reinforced the grand jury's broad investigative powers. The ruling significantly limits a witness's ability to later challenge the use of their testimony in a perjury prosecution, thereby strengthening the government's hand in policing false statements made during investigations. The sharp division in the concurrences, particularly Justice Brennan's opinion, highlights the unresolved tension between the grand jury's inquisitorial function and the Fifth Amendment rights of individuals who are effectively, if not formally, accused of a crime.
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