Thursday, December 5, 2013

Doyle v. Ohio case brief

Doyle v. Ohio case brief summary
426 U.S. 610 (1976)


CASE SYNOPSIS
On writ of certiorari to the Court of Appeals of Ohio, defendants challenged, as violative of their Due Process rights, the trial court's allowing a prosecutor to impeach their exculpatory story, told for the first time at trial, by cross-examining them about their failure to have told the story after Miranda warnings were given upon their arrest.

DISCUSSION

  • The court reversed defendants' convictions for the sale of drugs, determining that the trial court violated their rights under the Due Process Clause of U.S. Constitutional Amendment XIV by permitting the prosecutor to impeach their exculpatory story, told for the first time at trial, by cross-examining them on the fact that defendants failed to tell the story to police officers at the time of their arrest, after Miranda warnings were given. 
  • The court held that since defendants were advised that they had the right to remain silent, that anything they said could be used against them, and that they had a right to counsel before submitting to interrogation, silence in the wake of the warnings could have meant only that defendants were exercising their Miranda rights. 
  • Further, the warnings gave implicit assurance that silence would carry no penalty. 
  • The court ruled that under those circumstances, it would be fundamentally unfair and a deprivation of due process to allow defendants' silence to be used to impeach their explanation subsequently offered at trial.

CONCLUSION
The court reversed defendants' convictions for the sale of drugs because the prosecutor's use of defendants' silence, at the time of arrest and after receiving Miranda warnings, for impeachment purposes violated defendants' due process rights under the Fourteenth Amendment, as their silence could have been nothing more than the exercise of their Miranda rights, and the warnings carried an implied assurance that silence would carry no penalty.


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